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ETSI DTR 102 612 V 0.0.50(2008-09-24)
Final Draft for ESO TB approval
Human Factors (HF);
European accessibility requirements for public procurement
of products and services in the ICT domain
(European Commission Mandate M 376, Phase 1)
ETSI DTR 102 612 V 0.0.50 (2008-09-24)
1
Reference
DTR/HF-00095
Keywords
Accessibility, ICT, HF, Public procurement, Disability
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Contents
Intellectual Property Rights......
Foreword......
0Executive summary......
1Scope......
2References......
2.1Informative references......
3Definitions and abbreviations......
3.1Definitions......
3.2Abbreviations......
4Approach, methodology and contexts of use......
4.1Approach and methodology......
4.2User abilities and impairments......
4.3Contexts of use and user roles......
4.3.1Professional use......
4.3.2Consumer use......
4.3.3Combined use......
5ICT products and services bought by public procurers......
5.1General......
5.2International......
5.2.1United Nations Development Programme (UNDP)......
5.2.2World Trade Organisation (WTO)......
5.3European
5.3.1 European legislation
5.3.2CPV structure......
5.3.3CPV codes considered......
5.4National studies......
5.4.1General......
5.4.2 Types of ICT services and products procured......
5.4.3Procured mainstream products and services with accessibility requirements......
5.4.4Specific accessibility procurements......
5.5Summary and conclusions......
6Existing functional accessibility requirements for public ICT procurement......
6.1General......
6.2International requirements......
6.3Intra- and pan-European requirements......
6.4EU and EFTA Member state requirements......
6.4.1 Approach
6.4.2Conclusions
6.5Other national requirements......
6.6Summary and conclusions......
7Relevant European and international standards......
7.1General......
7.2Standards identified......
7.3Summary and conclusions......
8ICT user requirements and mapping......
8.1ISO/IEC DTR 29138-1: User requirements mapping......
8.1.1 Perception of visual information......
8.1.2 Perception of audio information......
8.1.3 Perception of available actions......
8.1.4 Perception of signals......
8.1.5 Perception of feedback......
8.1.6 Performing actions......
8.1.7 Time to complete actions......
8.1.8Intentional activation
8.1.9 Recovery from errors......
8.1.10 Security and privacy......
8.1.11 Safety......
8.1.12 Efficient operation......
8.1.13Understanding how to use......
8.1.14 Understanding output......
8.1.15 Using assistive technology......
8.1.16 Cross-cutting issues......
8.2UN Convention on the Rights of Persons with Disabilities: User requirements mapping......
8.2.1General......
8.2.2Article 9: Accessibility
8.2.4 Article 21: Freedom of expression and opinion, and access to information
8.3ETSI EG 202320: User requirements mapping......
8.3.1General......
8.3.2Real-time communication......
9Functional requirements......
9.1Introduction......
9.2Functional requirements......
9.2.1Closed functionality......
9.2.1.1Analysis......
9.2.2Biometric ID......
9.2.2.1Analysis......
9.2.3Pass through......
9.2.3.1Analysis......
9.2.4Audio information alternatives......
9.2.4.1Analysis......
9.2.5Visual information alternatives......
9.2.5.1Analysis......
9.2.6Colour......
9.2.6.1Analysis......
9.2.7Text size......
9.2.7.1Analysis......
9.2.8Speech operation alternatives......
9.2.8.1Analysis......
9.3Hardware......
9.3.1Reflectance contrast for legends and displays......
9.3.1.1Analysis......
9.3.2Flashing......
9.3.2.1Analysis......
9.3.3Mechanically operated controls......
9.3.3.1Analysis......
9.3.4Touch operated controls......
9.3.4.1Analysis......
9.3.5Standard connection......
9.3.5.1Analysis......
9.3.6Installed or free-standing products......
9.3.6.1Analysis......
9.3.7Hardware products with speech output or throughput......
9.3.7.1Magnetic coupling......
9.3.7.1.1Analysis......
9.3.7.2Interference with hearing device......
9.3.7.2.1Analysis......
9.3.7.3Audio connection......
9.3.7.3.1 Analysis......
9.3.7.4Volume......
9.3.7.4.1Analysis......
9.3.7.5Volume (gain)......
9.3.7.5.1 Analysis......
9.3.7.6Volume reset......
9.3.7.6.1 Analysis......
9.4Software and electronic content......
9.4.1Colour......
9.4.1.1Analysis......
9.4.2Contrast......
9.4.2.1Analysis......
9.4.3Perceptual characteristics......
9.4.3.1Analysis......
9.4.4User preferences......
9.4.4.1 Analysis......
9.4.5Colour adjustment......
9.4.5.1 Analysis......
9.4.6Non-text objects......
9.4.6.1 Analysis......
9.4.7Human (natural) language......
9.4.7.1 Analysis......
9.4.8Language of parts......
9.4.8.1Analysis......
9.4.9Pausing......
9.4.9.1Analysis......
9.4.10Flashing......
9.4.10.1Analysis......
9.4.11Consistent identification......
9.4.11.1Analysis......
9.4.12Audio turn-off......
9.4.12.1Analysis......
9.4.13Reading sequence......
9.4.13.1Analysis......
9.4.14Link purpose......
9.4.14.1 Analysis......
9.4.15Information and relationships......
9.4.15.1Analysis......
9.4.16User interface components......
9.4.16.1 Analysis......
9.4.17Disruption of access features......
9.4.17.1Analysis......
9.4.18Timing......
9.4.18.1Analysis......
9.4.19Keyboard operation......
9.4.19.1Analysis......
9.4.20Keyboard shortcuts......
9.4.20.1 Analysis......
9.4.21Focus indicator......
9.4.21.1Analysis......
9.4.22AT interoperability......
9.4.22.1 Analysis......
9.4.23Accessibility services......
9.4.23.1Analysis......
9.4.24Assistive technology......
9.4.24.1 Analysis......
9.4.25Multiple ways......
9.4.25.1Analysis......
9.4.26Labels or instructions......
9.4.26.1 Analysis......
9.4.27On focus......
9.4.27.1Analysis......
9.4.28On input......
9.4.28.1Analysis......
9.4.29Error identification......
9.4.29.1Analysis......
9.4.30Headings and labels......
9.4.30.1Analysis......
9.4.31Advisory recommendations......
9.4.31.1Suppression of unneeded function......
9.4.31.1.1Analysis......
9.4.31.2Writing guidelines......
9.4.31.2.1Analysis......
9.4.31.3Interaction guidelines......
9.4.31.3.1Analysis......
9.4.31.4Parsing......
9.4.31.4.1Analysis......
9.4.31.5User preferences (non-visual)......
9.4.31.5.1 Analysis......
9.5Audio visual equipment......
9.5.1Captioning/subtitling playback......
9.5.1.1Analysis......
9.5.2Supplemental audio playback......
9.5.2.1Analysis......
9.5.3Access to controls......
9.5.3.1Analysis......
9.6Audio/visual content......
9.6.1Captions and transcripts......
9.6.1.1Analysis......
9.6.2Audio description......
9.6.2.1Analysis......
9.6.3Interactive elements......
9.6.3.1Analysis......
9.7Real-time conversation......
9.7.1Real-time text reliability and interoperability......
9.7.1.1Analysis......
9.7.2Voice terminal hardware and software......
9.7.2.1Analysis......
9.7.3Voice mail, stored voice services and messaging......
9.7.3.1Analysis......
9.7.4Caller and status information......
9.7.4.1Analysis......
9.7.5Video support......
9.7.5.1Analysis......
9.7.6Audio clarity for VoIP......
9.7.6.1Analysis......
9.7.7External alerting devices......
9.7.7.1Analysis......
9.8Authoring tools......
9.8.1Accessible output......
9.8.1.1Analysis......
9.8.2Preserve accessibility information......
9.8.2.1Analysis......
9.8.3Prompts......
9.8.3.1Analysis......
9.8.4Accessible templates......
9.8.4.1Analysis......
9.9Information documentation and technical support......
9.9.1Accessible documentation
9.9.1.1Analysis......
9.9.2Keyboard shortcuts documentation......
9.9.2.1Analysis......
9.9.3Support services......
9.9.3.1Analysis......
9.10Implementation, operation and maintenance......
9.10.1Relay services accessibility......
9.10.1.1Analysis......
9.10.2Video support......
9.10.2.1Analysis......
9.10.3Accessibility configuration......
9.10.3.1Analysis......
9.10.4Accessible content......
9.10.4.1Analysis......
9.11Documents consulted......
9.11.1Published documents consulted......
9.11.2Draft documents consulted......
10Gaps in accessibility requirements......
10.1New user accessibility requirements......
10.1.1User requirements not addressed......
10.2Additional functional requirements
10.2.1Non speech audio......
10.2.2Vibration patterns......
10.2.3Monaural audio......
10.2.4Foreground audio discrimination......
10.2.5Adjustable pitch and balance......
10.2.6Information describing layout......
10.2.7Adjustable pitch and balance......
10.2.8Co-location of feedback......
10.2.9Physical connection feedback......
10.2.10No direct contact......
10.2.11Signed description......
10.2.12Speech only operation......
10.2.13Protection of information......
10.2.14Security of information......
10.2.15Avoiding hazards......
10.2.16Avoiding injury......
10.2.17Audio induced seizure......
10.2.18Electromagnetic allergy......
10.2.19Chemical allergy......
10.2.20Alternate modes effective......
10.2.21Adjust rate of audio alternatives......
10.2.22System preferences take immediate effect......
10.2.23Return system preferences to defaults......
10.2.24Structure in long audio documents......
10.2.25Wording and symbols easy to understand......
10.2.26Words and symbols use standard conventions......
10.2.27Clear and easy mechanisms for access features......
10.2.28Support different thinking styles......
10.2.29Assistance in understanding hierarchical products......
10.2.30Reducing operation steps......
10.2.31Reducing memory requirements......
10.2.32Simple interfaces......
10.2.33Each function on its own key......
10.2.34Knowing a product is usable and how to set it up......
10.2.35Information presented in non text form......
10.2.36Wording clear and simple as possible......
10.2.37Ability to comprehend access information......
10.2.38Feedback as pictures or symbols......
10.2.39Alternatives to text......
10.2.40Alternatives to figures of speech......
10.2.41Multiple disability......
10.2.42Editing functions for communication......
10.2.43Emergency text communications......
10.2.44Multi party text communications......
10.2.45Information about colour and symbol use......
10.2.46Signed description......
10.3Summary and conclusions......
11Conclusions and considerations for M 376 Phase II (and beyond)......
11.1 General conclusions......
11.2Standardisation work programme considerations
11.3Required deliverables......
11.4Other deliverables required by Phase II
11.5Additional recommendations and considerations......
Annex A (informative): US Section 508 and the Canadian toolkit......
A.1 General......
A.2US (Section 508)......
A.2.1The purpose of Section 508......
A.2.2The Access Board......
A.2.3Agencies' responsibilities......
A.2.4The role of the GSA......
A.2.5Application of Section 508......
A.2.6Technical requirements under Section 508......
A.2.7Section 508 accessibility: The b b......
A.2.8The Voluntary Product Accessibility Template™ (VPAT™)......
A.2.8.1General......
A.2.8.2How the VPAT is organized......
A.2.9Update of the 508 Standards and the Telecommunications Act Guidelines ("508 Refresh")
A.2.9.1TEITAC......
A.3The Canadian Accessible Product Toolkit (APT)......
A.3.1General......
A.3.2Product and service categories......
A.3.3Data links......
A.3.3.1Definition......
A.3.3.2Requirements......
A.3.3.3Advice......
A.3.3.4Environmental considerations......
A.3.4Product Codes on the APT......
A.3.5Example......
Annex B (informative): List of applicable CPV codes
Annex C (informative): Procurement legislation and ICT products and services procured in the EU and EFTA Member states
C.1Process and results
C.2Austria
C.2.1Procurement legislation
C.2.2Products and services procured......
C.3Belgium......
C.3.1Procurement legislation......
C.3.2Products and services procured......
C.4Bulgaria......
C.4.1Procurement legislation......
C.4.2Products and services procured......
C.5Cyprus......
C.5.1Procurement legislation......
C.5.2Products and services procured......
C.5.2.1Hardware......
C.5.2.2Services......
C.5.2.3Software......
C.6Denmark......
C.6.1Procurement legislation......
C.6.2Products and services procured......
C.7Estonia......
C.7.1Procurement legislation......
C.7.2Products and services procured......
C.8Finland
C.8.1Procurement legislation
C.8.2Products and services procured......
C.9France......
C.9.1Procurement legislation......
C.9.2Products and services procured......
C.10Germany......
C.10.1Procurement legislation......
C.10.2Products and services procured......
C.11Greece......
C.11.1Procurement legislation......
C.11.2Products and services procured......
C.12Hungary......
C.12.1Procurement legislation......
C.12.2Products and services procured......
C.13Iceland......
C.13.1Procurement legislation......
C.13.2Products and services procured......
C.14Ireland......
C.14.1Procurement legislation......
C.14.2Products and services procured......
C.15Italy......
C.15.1Procurement legislation......
C.15.2Products and services procured......
C.16Latvia......
C.16.1Procurement legislation......
C.16.2Products and services procured......
C.17Liechtenstein......
C.17.1Procurement legislation......
C17.2Products and services procured......
C.18Lithuania......
C.18.1Procurement legislation......
C.18.2Products and services procured......
C.19Luxembourg......
C.19.1Procurement legislation......
C.19.2Products and services procured......
C.20Malta
C.20.1Procurement legislation
C.20.2Products and services procured......
C.21Netherlands......
C.21.1Procurement legislation......
C.21.2Products and services procured......
C.22Norway......
C.22.1Procurement legislation......
C.22.2Products and services procured......
C.23Poland......
C.23.1Procurement legislation......
C.23.2Products and services procured......
C.24Portugal
C.24.1Procurement legislation
C.24.2Products and services procured......
C.25Romania......
C.25.1Procurement legislation......
C.25.2Products and services procured......
C.26Slovakia
C.26.1Procurement legislation
C.26.2Products and services procured......
C.27Slovenia......
C.27.1Procurement legislation......
C.27.2Products and services procured......
C.28Spain......
C.28.1Procurement legislation......
C.28.2Products and services procured......
C.29Sweden......
C.29.1Procurement legislation......
C.29.2Products and services procured......
C.29.2.1Products......
C.29.2.2Services......
C.29.2.3Software......
C.30Switzerland......
C.30.1Procurement legislation......
C.30.2Products and services procured......
C.31UK......
C.31.1Procurement legislation......
C.31.2Products and services procured......
Annex D (informative): National eAccessibility procurement requirements......
D.1Procurement requirements in EU and EFTA Member states......
D.1.2Austria......
D.1.3Belgium......
D.1.4Bulgaria......
D.1.5Cyprus......
D.1.6Denmark......
D.1.7Estonia......
D.1.8Finland......
D.1.9France......
D.1.10Germany......
D.1.11Greece......
D.1.12Hungary......
D.1.13Iceland......
D.1.14Ireland......
D.1.15Italy......
D.1.16Latvia......
D.1.17Liechtenstein......
D.1.18Lithuania......
D.1.19Luxembourg......
D.1.20Malta......
D.1.21Netherlands......
D.1.22Norway......
D.1.23Poland......
D.1.24Portugal......
D.1.25Romania......
D.1.26Slovakia......
D.1.27Slovenia......
D.1.28Spain......
D.1.29Sweden......
D.1.30Switzerland......
D.1.31UK......
D.2Other national requirements......
D.2.1Australia......
D.2.2Canada......
D.2.3Japan......
D.2.4United States......
Annex E (informative): Standards with accessibility requirements......
E.1International standards
E.1.1Published standards
E.1.2Standards under development......
E.2European standards......
E.2.1Published European standards......
E.2.2European standards under development......
E.3National standards in Europe......
E.3.1Spain......
E.3.2United Kingdom......
E.4Other national standards......
E.4.1Australia......
E.4.2Japan......
E.4.3Republic of Korea
E.4.3.1Published standards
E.4.3.2Draft standards......
Bibliography......
History......
Intellectual Property Rights
IPRs essential or potentially essential to the present document may have been declared to ETSI. The information pertaining to these essential IPRs, if any, is publicly available for ETSI members and non-members, and can be found in ETSISR000314: "Intellectual Property Rights (IPRs); Essential, or potentially Essential, IPRs notified to ETSI in respect of ETSI standards", which is available from the ETSI Secretariat. Latest updates are available on the ETSI Web server (
Pursuant to the ETSI IPR Policy, no investigation, including IPR searches, has been carried out by ETSI. No guarantee can be given as to the existence of other IPRs not referenced in ETSISR000314 (or the updates on the ETSI Web server) which are, or may be, or may become, essential to the present document.
Foreword
This Technical Report (TR) has been produced by ETSI Technical Committee Human Factors (HF). The work was co-funded by the EC/EFTA in response to Phase I of EC Mandate M 376 [136], and was developed in close coordination with CEN BT WG 185 and CENELEC CLC-BT WG 101-5, during September 2007- September 2008.
0Executive summary
The present document was prepared in response to the ETSI part of Phase I of Mandate M 376 [135] from the European Commission to CEN, CENELEC and ETSIwhich requires the provision of an inventory of European and international accessibility requirements in order to harmonize and facilitate the public procurement of accessible ICT products and services.
The Mandate required the generation of an inventory of ICT products and services together with a listing of the functional accessibility requirements of those products.
An initial study of the Common Procurement Vocabulary (CPV) code list revealed that over 100 ICT product categories or products could be identified as products that might be bought by public procurers. The range of ICT products and services actually purchased through government procurement services were determined in a study conducted using the codes listed in Tenders Electronic Daily (TED) (see and through questioning of national representatives throughout Europe and in other Countries.
The main products identified in this study were computer hardware, photocopying and printing equipment, telecommunications equipment, software, installation, configuration and set-up services, maintenance services, upgrade services, customization and telecommunication services (e.g. fixed and mobile telephony). The study is described in Clause 5 and those few ICT products and services publicly referred to in national information are set out in more detail in Annex C, which also contains references to national procurement legislation.
It was noted that TED can provide an open and transparent record of products and services purchased by Government agencies but the level of information varied significantly between countries, the difference to some extent reflecting the relative maturity of national procurement legislation.
Furthermore it was found that this procurement information could be distorted by certain National practices. In many Countries the national regulator uses the obligations of the Universal Service Directive [23] to mandate the provision of accessible products and services by an operator with significant market power. This generates a hidden procurement-like situation without any payment appearing between a Government and the affected telecom operator. Thus there is no public information on the products procured. It was also found that there are differences in the level of obligation demanded in different Countries.
A review that was made of the existing functional accessibility requirements used for public procurement within Europe and in other countries showed that only a few steps have been taken to advance eAccessibility through public procurement. This review is reported in Clause 6 with more detail given in Annex D.
At an International level,the UN Convention on the Rights of Persons with Disabilities [149] advances measures that promote eAccessibility to information, communications and other services.
At an intra-European level, the Nordic Forum for Telecommunication andDisability provides guidelines and recommendations related to eAccessibility. International and European standardisation bodies have been preparing standards and recommendations related to eAccessibility and these standards have been identified.
Related information for each member state and EFTA country is detailed in Annex D. In general, the main existing accessibility requirements in EU member States and EFTA countries refer to the Web accessibility of either existing or new public Web sites. There are some countries that mandate the accessibility of the Web sites of their public organisations. Others advance Web accessibility but not within any legal framework and a few have no particular evidence of Web accessibility.
There are two European countries (Italy and Spain) where the national law mandates accessible ICT procurement based on international, European and national standards. There are also two counties (Denmark and Ireland) that have developed public procurement toolkits that enable procurers to address accessibility requirements in their procurement procedures on a voluntary basis.
Outside Europe, in the USA, the requirements for accessibility are set out in the Code of Federal Regulations (in CFR 36, Part 1194). These are currently being reviewed and updated under the "Section 508 Refresh" and have been considered thoroughly in several clauses in this report. AustralianCommonwealth departments and agencies are required by the Disability Discrimination Act 1992 to ensure that online information and services are accessible by people with disabilities. In Japan, products and services supplied to the government must have considered ICT accessibility based in a series of existing standards.
Exhaustive research was conducted into the large number of documents related to accessibility that have been or are being produced by international and regional Standards Development Organisations. This work is reported in Clause 7. Some of these documents provided a valuable source of information on user needs related to particular disabilities. Unfortunately the functional requirements set out in many of the standards were exceedingly vague and commonly referred out to other documents which in their turn contained no testable requirements.
Over 100 documents dealing with accessibility related functions were identified in this study. This huge list of requirements and standards may be overwhelming for those working with specifications for procurement who also have many other aspects than accessibility to consider. It seems inevitable that some practical guidance is needed to pick those applicable standards best suited for reference in procurement documents. Some countries have introduced a toolkit for retrieval of requirements and standards for the application at stake. This approach seems to provide a practicable resolution for this task.
New ways to operate ICT are created continuously, and new ways will appear to fulfil user needs. New standards will therefore be needed to harmonize such new features, and they will have to be incorporated into tools for selecting requirements and standards. Thus any list of standards must be a living list with proper maintenance.
In order to determine what gaps existed in current accessibility requirements for ICT equipment, a study was first made of ISO/IEC PDTR 29138-1 [113] and of other documents such as the UN convention on the rights of persons with disabilities [149] to determine those needs of users with disabilities that required to be satisfied by such accessibility requirements. These user needs are set out in Clause 8 and each need is mapped with an existing functional technical requirement for features and facilities of ICT products where it was found. This mapping was very valuable in identifying a significant number of apparent "gaps" between the needs of disabled users expressed in those documents and the technical requirements available to satisfy these needs.
This approach, by relating user needs to a product feature (for example, a display), was found to be the most effective way of dealing with the requirements as the user needs are similar for any product with that feature. This was more efficient than attempting to generate a listing of all possible CPV codes for products that might contain a display and associating the functional requirements for a display with each.
Relating the technical accessibility requirements to the users needs and features, as was done in the ETSI Design for All guide EG 202 116 [32], limits the effect of this combinatorial complexity issue and was therefore the approach taken in this report.
It should be noted that at the time of writing this report, ISO/IEC PDTR 29138-1 [113] is still a draft and that some of the expressed "needs" may not survive into the finally published version, either because they are not specific to disabled users or because they are not considered to be real or subject to practicable solution.
Clause 9 provides a detailed listing of those existing functional requirements together with a reference to those clauses found in existing standards or drafts which refer to that requirement.
The user needs set out in Clause 8 which do not have an associated functional requirement in Clause 9 are listed in Clause 10 and identified as potential "gaps". Some process will be required to study these theoretical "gaps" to determine whether they can or should be "filled" or whether further research is needed. This study needs to be carried out in a suitable forum where global consensus can be achieved. Such a forum should at least include the European Commission and the US Access Board.
This global work implies a timescale longer than that projected for Phase II of the Mandate and suggests that gap filling measures should be performed outside the mandated Phase II work, preferably in international collaboration including research and standardisation.
Clause 11 draws conclusions from the studies set out in the report, presents input to a Standardization work programmeand makes proposals for the work of Phase II of the Mandate.
It is proposed that for each functional requirement, a review is made of those references that have been identified and a new functional requirement is written that forms a consensus of those existing technical statements. Such an approach could provide a comprehensive document that could provide a "one stop shop" where all the necessary functional requirements of an ICT product or service could be found. It would also avoid potential copyright problems caused by a listing of extracts from other standards.
The mapping performed in Clauses 8 and 9 demonstrated that there was sufficient information available to provide a firm base for the creation of a single European norm which could address the majority of identified user needs and which could contain functional requirements which are demonstrable and testable.
Some process will be required to study those theoretical "gaps" between the currently available functional requirements and the needs of disabled users. This study will need to be carried out in a suitable forum where global consensus can be achieved. Such a forum, which would be outside of the Phase II work, should at least include the European Commission and the US Access Board (on policy as well as at operational levels).