Fax Machines, Copiers, Printers, and Other IT Office Equipment(1)

Most fax machines, copiers, printers, and other IT office equipment contain barriers to access by people with disabilities. For instance, most copiers give error messages on liquid crystal display (LCD) screens that are generally inaccessible to people who are blind or who have low vision. Many LCD screens are angled so that they are difficult or impossible for people who use wheelchairs to read them. People with other types of disabilities encounter different barriers.

Agencies generally found that when they used IT office equipment that was attached to their computer network, many of these barriers were eliminated. Most networked office equipment is designed to communicate with the user while he or she is at his or her workstation. Desktop computers can be easily equipped with assistive technology, such as screen readers, for people with disabilities.

The Evaluation Tools

Components of federal agencies were asked to evaluate in terms of accessibility, both objectively and subjectively, their 10 most commonly used items in the category containing fax machines, copiers, printers, and other types of IT office equipment. The components used the "IT Equipment Accessibility Checklist" developed by the Department of Justice for the objective portion of their survey.

For each of the 10 items falling within the category of "Other IT Equipment," components were instructed to provide the following information:

In addition to answering objective-format questions for each item, components were directed to have users with a wide variety of disabilities test the equipment for accessibility, and report on their accessibility challenges and successes. Agencies were also asked to make recommendations for improvements.

I. Objective Survey Tool: The "IT Equipment Accessibility Checklist"

Many of the concepts in the Department's IT Equipment Accessibility Checklist (Checklist) were drawn from the Americans with Disabilities Act's Standards for Accessible Design (ADA Standards), 36 C.F.R. part 36, Appendix A, as well from other sources. This Checklist was intended to facilitate a quick review of the accessibility of office equipment such as printers, fax machines and copiers, that are commonly used in the modern workplace and were not captured by the accessibility surveys of web pages, software, information transaction machines, or telecommunications products.

To aid the reader, this section is divided into three subparts:

A. Review of Survey Questions

1. Can the user change sound settings, such as volume?

Question 1 of the IT Equipment Accessibility Checklist mirrors Question 1 of the ITM Accessibility Checklist. Both are based on the work of the Trace Research and Development Center of the University of Wisconsin-Madison. People who are hard of hearing frequently may need sound amplification to use all features of IT office equipment. People who are hard of hearing and who have other disabilities may also be excluded if the IT office equipment does not allow the user to change sound settings.

Because some IT equipment may not emit sounds as information to the user, an answer of "not applicable" does not necessarily indicate a problem with accessibility.(2) In 25% (380 of 1,498) of the surveys, components indicated that the IT equipment does not have adjustable sound settings. See Table 1.

2. Are any displays including liquid crystal displays readable by persons who are in a seated position, such as those who use wheelchairs?

Question 2 reflects the practical need for allowing persons who use wheelchairs to be able to see the information displayed by the IT equipment. For instance, some large, free-standing office copier machines use flat panel displays that are parallel to the ground. The information conveyed through the display may be unreadable to persons who use wheelchairs, especially if the display uses liquid crystal displays.

Since it is possible (although unlikely) that an item of IT equipment being evaluated does not have a display, an answer of "not applicable" may not necessarily indicate a problem with accessibility. In 16% (240 of 1,498) of the surveys, components indicated that features on the IT equipment cannot be read by seated users, including those who use wheelchairs. See Table 2.

3. For free-standing equipment, is the highest operable part of controls, dispensers, receptacles, and other operable equipment placed within at least one of the following reach ranges?

(a) If a forward approach is required, the maximum high forward reach is 48 inches.

(b) If a side approach is allowed, and the reach is not over an obstruction, the maximum high side reach is 54 inches; if it is over an obstruction which is no more than 24 inches wide and 34 inches high, the maximum high side reach is 46 inches.

Question 3 is drawn from the Uniform Federal Accessibility Standards (UFAS), which apply to federal facilities under the Architectural Barriers Act. 42 U.S.C. §§ 4151 et seq. The ADA Standards contain identical requirements. See ADA Standards §§ 4.2.5 and 4.2.6.

Free-standing EIT equipment, particularly large office copiers, can present a host of accessibility problems for persons who use wheelchairs. Unlike portable office equipment, which can be moved to different locations to facilitate access by persons using wheelchairs, free-standing equipment is usually placed in a fixed location. If the design of that equipment incorporates elements that are too high, it may be inaccessible to a person who uses a wheelchair.

Where modern EIT equipment is portable and not free-standing, a response of "not applicable" is acceptable without affecting accessibility. In 8% (116 of 1,498) of the surveys, components indicated that the IT equipment includes operating controls that are outside the allowable reach ranges. See Table 3.

4. Are status information and cues that are provided in a visual manner also available in an audible manner for persons with visual impairments?

Question 4 of the IT Equipment Accessibility Checklist mirrors Question 2 of the ITM Accessibility Checklist. Both are based on the truism that visual information may be ineffective for users who are blind or who have low vision or other disabilities affecting vision. Some persons with cognitive impairments or learning disabilities may also be affected by the sole reliance on visual information, especially those who cannot read or discern complicated visual information.

Because certain IT equipment may not provide any visual display of information, a "not applicable" response by a component does not necessarily indicate a problem with the equipment's accessibility. In 77% (1,159 of 1,498) of the surveys, components indicated that the IT equipment models do not provide visual status information and cues in an audible format as well as through visual means. See Table 4.

5. For fax machines, does the machine provide line status information (such as notifying the user of a "busy" fax line) in a visual manner (either text display or status lights) for users who are deaf or hard of hearing?

Question 5 of the IT Equipment Accessibility Checklist mirrors Question 7 of the ITM Accessibility Checklist. These questions relate to a user's ability to hear; both ask whether visual information is provided for all audible information. It is important to provide visual cues and information for all sound cues and audible information to make IT equipment accessible to people who are deaf or hard of hearing.

Because Question 5 is limited to fax machines and does not relate to other forms of IT equipment, a response of "not applicable" has no bearing on accessibility. In less than 5% (69 of 1,498) of the surveys, components indicated that the fax machines do not provide visual displays for all information. This percentage reflects the total number of surveys of IT office equipment, not the total number of surveys of fax machines. See Table 5.

6. Is the force required to operate or activate controls no greater than 5 lbf?

Question 6 relates to whether the equipment requires the user to expend a large amount of force to activate or operate its controls. If so, a barrier may exist for people with disabilities limiting strength or manual dexterity. Question 6 was drawn from provisions in UFAS and the ADA Standards.

Because all types of commonly used office EIT equipment use some combination of switches or controls (at the very least, an "on/off" switch), a "not applicable" answer indicates that the evaluator likely misread or misunderstood the question, had no instrument to measure force, or that he or she was trying to avoid choosing the "inaccessible" answer.(3) Therefore, the Department considered the "yes" answers to be more accurate than the "no" answers or than the "no" answers combined with the "not applicable" responses. In 75% (1,117 of 1,498) of the surveys, components indicated that the IT equipment has operating mechanisms that does not require more than 5 pounds of force to operate. See Table 6.

7. Can users confirm their selections?

For instance, if a person has limited fine motor control, such as a person who has a palsy, it is helpful for him or her to have the opportunity to confirm selections such as "number of copies" selected before the operation begins.

Modern office equipment often allows the user to choose among a variety of functions. A copier may include options for collating copies, making double-sided copies, and making multiple copies. For a person with limited dexterity or motor control, this complexity may change what would otherwise be a relatively simple task -- such as copying -- into a difficult task if he or she inadvertently hits the wrong button. One way to lessen the likelihood of mistakes is to allow users to confirm their selections before performing a task.(4) Persons with cognitive impairments or some learning disabilities may also benefit from the ability to review selections before operations begin.

Certain types of office equipment, however, may not be intended for users to make selections. A printer, for instance, may be configured to respond to "print" requests from users on a computer network. Individual users may have no reason to make selections on the unit itself. Therefore, a "not applicable" response may be appropriate without reflecting on the accessibility of the unit reviewed. In 13% (192 of 1,498) of the surveys, components indicated that the IT equipment does not allow users to confirm their selections. See Table 7.

8. Are controls and operating mechanisms operable with one hand and operable without tight grasping, pinching, or twisting of the wrist?

Question 8 addresses another issue that may affect usability of IT equipment for persons with limited strength or manual dexterity. It is based on similar language in UFAS and the ADA Standards.

As previously noted, all or almost all IT equipment has operating mechanisms or controls. Therefore, responses of "not applicable" are analyzed as though they were "no" answers. In close to 10% (144 of 1,498) of the surveys, components indicated that the IT equipment includes operating mechanisms that require tight grasping, twisting, or pinching, thus posing barriers for people with disabilities affecting strength or manual dexterity. See Table 8.

9. Is there a headphone jack for accessing information by users of assistive listening systems?

Question 9 mirrors Question 8 of the ITM Accessibility Checklist. Many users who are hard of hearing may require a tailored means of listening (such as through assistive technologies). For office equipment that uses audible cues or information, providing a standard headphone jack (which permits users to use standard headphones, T-coil connections, or other types of assistive technology) can be a practical way of improving access. A particular item of IT equipment can be accessible to people who are deaf or hard of hearing if all audible information is also provided in a visual format (see Question 5). However, absence of a headphone jack or other means of using assistive technology is particularly significant to people who are both hard of hearing and who are blind or who have low vision.

If IT equipment does not provide any audible information, one might conclude that "not applicable" could be an appropriate response to Question 9. So long as the equipment provides visual information to users, it should provide the same information in an audible format for persons who cannot see. Therefore, the only appropriate answer to Question 9 is "yes" or "no." All "not applicable" responses have been treated as potentially indicating a problem with accessibility. In 94% (1,409 of 1,498) of the surveys, components indicated that the IT equipment does not include a headphone jack. See Table 9.

10. Are instructions and all information for use accessible to and independently usable by persons with vision impairments, such as with recorded information or Braille labels and directions?

User instructions should be available in multiple formats so that they will be usable by everyone. Users who are blind and some with low vision may require instructions to be available in an audible format. When the equipment is designed for use with computers, providing instructions in a computerized format will generally provide accessibility, as those who need information to be presented audibly or in Braille can access it with screen readers. Other types of IT equipment may not be intended to always be used in conjunction with computers and may be deployed where computers are unavailable. Electronic format instructions will be of little use in this circumstance.

Ex: A ranger station in a national park may have a telephone (or cellular phone) and a fax machine, but not a computer. In these situations, having instructions and documentation available in an electronic format may not be a practical means of making such information accessible to and independently usable by people who are blind or have low vision.

When IT equipment is not made accessible through providing information in an electronic format, having the information available audibly or in Braille (preferably, in both formats) may be needed to make the instructions available to everyone.(5)

A "not applicable" response may be appropriate if user information is unavailable or not provided to anyone. While user information is unavailable only in rare circumstances, and is only likely to occur with very old equipment, some components may have appropriately selected the "not applicable" response to Question 10; such responses were not deeded to reflect negatively on the accessibility of the equipment surveyed. In 86% (1,285 of 1,498) of the surveys, components indicated that the IT equipment does not have instructions that are independently accessible to users who are blind or who have low vision. See Table 10.

11. Are there alternate operating mechanisms for persons who cannot use push-style controls?

Ex. For instance, are there alternative methods of control such as voice activation for routine tasks?

Question 11 asks whether the IT equipment is accessible to them.

Many types of modern office equipment use push-button controls, often integrated into a single panel. Some people have disabilities that make it impossible for them to use push-style controls. Other machines use "touch-sensitive" display panels. Both of these operating mechanisms are difficult (or impossible) for people who are blind, those with low vision, and some people with disabilities affecting mobility or dexterity. Providing an option to enable users to activate and control the equipment's operations through voice input can make office equipment accessible to many people who would not otherwise be able to use it without assistance.

Although it is unlikely that a particular item of IT equipment will not have operating mechanisms, it is possible that the only controls are basic controls such as a power switch. Designers should think about replacement or supplementation of such basic maintenance controls with alternate forms of input during the early stages of the design process rather than trying to retrofit existing equipment. A "not applicable" response may be appropriate without adversely affecting the item's accessibility rating for the purposes of this Report. In 83% (1,248 of 1,498) of the surveys, components indicated that the IT equipment does not include alternate operating mechanisms for users who cannot use push-style controls. See Table 11.

Summary of Impact on Disability Categories

The following chart (D) summarizes the survey questions and the disability categories that are affected by responses to those questions:

 
Questions
Affecting the community of users who: 1 2 3 4 5 6 7 8 9 10 11
- are hard of hearing x       x       x    
- are deaf         x            
- have combined disabilities affecting hearing and vision x     x x       x x x
- are blind       x           x x
- have low vision       x           x x
- have tremors or limited strength or dexterity           x x x     x
- have some form of a cognitive impairment or learning disability       x     x       x
- use wheelchairs   x x                

B. Objective Survey of Accessibility by Disability Category

The chart above provides a summary of the how answers to the IT Office Equipment Accessibility Checklist would affect different communities of users with disabilities. Different individuals within each community may find different features important for accessibility.

1. Users Who are Deaf or Hard of Hearing

Questions 1, 5, and 9 address accessibility issues that affect users who are hard of hearing. In 1.7% (25 of 1,498) of the surveys, components indicated that the IT equipment does not provide accessibility in all three areas. In 94% (1,415 of 1,498) of the surveys, components indicated that the IT equipment does not provide accessibility in at least one of these areas. See Table 12.

2. Users Who are Deaf

Question 5 is the only question which addresses an accessibility issue for IT office equipment for people who are deaf. The question is limited to fax machines, because relatively few other types of IT office equipment rely on sound as the sole method of conveying important status information or cues to users. In 5% (69 of 1,498) of the surveys, components indicated that the fax machines do not provide a visual means of conveying information that is otherwise presented audibly. See Table 5.

3. Users Who Have Disabilities Affecting Both Vision and Hearing

Six questions (Questions 1, 4-5, and 9-11) address issues that affect usability by users with some combination of both hearing and visual disabilities. In less than 2% (22 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible as measured by all six questions. In less than 99% (1,477 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible in at least one of these respects. See Table 13.

It is also important to determine how different subgroups of users with combinations of disabilities are affected by the issues raised in these questions. Each of the following four subgroups of users is affected by a different subset of these six questions, as shown in the following chart: (D)

Community of Users

Questions Affecting This Subgroup of Users
People who are hard of hearing and blind 1, 4, 9, 10, 11
People who are hard of hearing and who have low vision 1, 4, 5, 9, 10, 11
People who are deaf and blind 10, 11
People who are deaf and who have low vision 5, 10, 11

People who are hard of hearing and blind are affected by issues raised in Questions 1, 4, 9, 10, and 11. In 21.3% (319 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible in all of the areas touched upon by these questions. In 98.6% (1,477 of 1,498) of the surveys, components indicated that the IT equipment includes at least one of these potential barriers to this community of users with disabilities. See Table 14.

People who are hard of hearing and who have low vision are affected by issues raised in all six questions. See Table 13.

People who are both deaf and blind, by contrast, are affected by issues raised in Questions 10 and 11. In 81.1% (1215 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible in both of the areas touched upon by these questions. In 88% (1,318 of 1,498) of the surveys, components indicated that the IT equipment has at least one barrier to this community of users. See Table 15.

Finally, people who are deaf and who have low vision are affected by issues raised in Questions 5, 10, and 11. In 4% (65 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible to this community of users in all three respects; 88% (1,320 of 1,498) indicated that the IT equipment poses at least one potential barrier to this community of users. See Table 16.

4. Users Who Are Blind or Who Have Low Vision

Questions 4, 10, and 11 raise issues that affect people who are blind or who have low vision. In 71% (1,059 of 1,498) of the surveys, components indicated that the IT equipment poses barriers in all three areas raised by these questions. In 90% (1,349 of 1,498) of the surveys, components indicated that the IT equipment poses at least one potential barrier for this community of users. See Table 17.

5. Users Who Have Tremors and Those with Disabilities Limiting Strength or Manual Dexterity

People who have tremors or disabilities limiting strength or manual dexterity are affected by the issues raised in Questions 6-8 and 11. In 1.5% (22 of 1,498) of the surveys, components indicated that the IT equipment poses barriers in all four of the areas touched upon by these questions. In 87.6% (1,316 of 1,498) of the surveys, components indicated that the IT equipment poses at least one potential barrier for this community of users. See Table 18.

Barriers to this community can be further analyzed by creating more subtle distinctions among the disability categories: (D)

Categories

Questions Affecting Each Subgroup of Users
People with tremors or who have limited manual dexterity 7, 8, 11
People with limited strength 6, 8

People who have tremors or who have limited manual dexterity are affected by issues raised in Questions 7, 8, and 11. In 2.3% (35 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible in all three areas raised by these questions. In 86.6% (1,297 of 1,498) of the surveys, components indicated that the IT equipment poses at least one potential barrier to this community. See Table 19.

People with disabilities limiting strength are affected by issues raised in Questions 6 and 8. In 5.5% (83 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible with respect to the issues raised in both questions. Furthermore, in 29.5% (442 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible in at least one of these respects. See Table 20.

6. People with Cognitive Impairments or Learning Disabilities

People with cognitive impairments and learning disabilities are affected by issues raised in Questions 4, 7, and 11. In 12% (173 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible in all three areas raised by these questions. In addition, in 89% (1,336 of 1,498) of the surveys, components indicated that the IT equipment is inaccessible in at least one of these three respects to some persons with cognitive impairments and learning disabilities. See Table 21.

7. People who use wheelchairs

Persons who use wheelchairs are affected by issues raised in Questions 2 and 3. In 4% (63 of 1,498) of the surveys, components indicated that the IT equipment contains barriers addressed in both questions. In 19% (293 of 1,498) of the surveys, components indicated that the IT equipment contains at least one potential barrier to people who use wheelchairs. See Table 22.

II. Subjective Evaluations

The IT Equipment Accessibility Checklist also contained instructions to carry out a more subjective evaluation:

Question 12. After you have evaluated this equipment using the Checklist, have users with a wide variety of disabilities test it for accessibility. Describe the accessibility successes and problems they encountered during these exercises, as well as your plans for addressing any problems.

Components' answers to Question 12, combined with the narrative overall agency reports, provided a wealth of information. Particularly useful were descriptions of current model programs and agencies' recommendations for making IT equipment more accessible.

Approximately two-thirds of component surveys of IT office equipment contained meaningful responses to Question 12.

In 78 surveys, components indicated that the equipment posed no barriers to people with disabilities.

Many of the surveys contained comments that indicate there is still some confusion regarding agencies' different legal obligations under sections 501 and 504 of the Rehabilitation Act, compared to those in section 508:

Agencies should separate the reasonable accommodation issue of sections 501/504 from the 508 issue of examining their IT office equipment for general accessibility to persons with disabilities. These legal obligations are not inconsistent. For instance, section 508 requires that agencies procure information technology that is consistent with the Section 508 Standards ultimately promulgated by the Access Board, unless doing so imposes an undue burden. Even when agencies have complied with the Section 508 Standards, if a qualified person with a disability has needs that go beyond those addressed by the Section 508 Standards, and if a reasonable accommodation can be made without imposing an undue burden or fundamentally altering the agency's program, the agency must provide that reasonable accommodation. As the federal environment becomes more reliant on technology, agencies that do not comply with section 508 will find it more difficult to meet their reasonable accommodation obligations under sections 501 and 504 of the Rehabilitation Act. Agencies cannot continue to rely on their ability to provide accommodations on an ad hoc basis. Instead, they must now consider accessibility whenever they develop, procure, maintain, or use electronic and information technology.

Many agencies indicated that it was difficult or impossible to subjectively evaluate their IT office equipment:

However, many agencies are showing leadership and creativity in assessing and addressing the accessibility of their IT office technology equipment (and other types of EIT):

Only 29 of the overall agency reports addressed IT office equipment accessibility, generally reflecting the same concerns raised in the component surveys. In 19 of these reports, agencies acknowledged the existence of some accessibility difficulties with their IT office equipment. Some of the more specific observations included:

More importantly, the response from the Department of Labor reflected a very positive commitment to improving accessibility. This statement of an agency's commitment, which appears below, should be a model for other agencies.

Promising Practice imageD

III. Recommendations

To address the barriers discussed in this Report, the Department recommends the following:

1. Instructions. Many times, office machines contain accessible features, such as a volume control mechanism on a fax machine, but instructions on how to use these features are missing or inadequate. Each agency should survey its fax machines, copiers, and printers and, if appropriate, contact vendors for a full list of accessible features. The agency should provide clear instructions in accessible formats.

2. Networked IT Office Equipment. The extent to which copiers and fax machines are accessible is greatly enhanced when the user can send commands from an attached desktop computer terminal (such terminals may be easily outfitted with the appropriate assistive technology to meet an individual's needs). Each agency should, in appropriate circumstances, seek out network solutions over stand-alone machines when such solutions would provide a greater degree of accessibility for employees and members of the public with disabilities.

3. Instructions for Alternatives. For inaccessible IT office equipment that is available to the general public or a large number of employees, each agency should ensure that accessible instructions are available on how a person with a disability can obtain accessible alternative services (such as where to seek assistance).


1. This document is available on the Department of Justice's section 508 Web site (www.usdoj.gov/crt/508). People with disabilities may request copies in Braille, large print, or on computer disk by calling 1-800-514-0301 (voice) or 1-800-514-0383 (TTY).

2. On each of the "Checklists," the Department structured the objective-format questions such that the answer indicating that a product was more accessible was almost always "yes," while the answer indicating that a product likely contained barriers was usually "no." Each page of the Checklists accordingly stated, "Any 'no' answer may indicate a problem with accessibility." Some evaluators may have selected "not applicable" as a response, even when doing so was inappropriate, to avoid choosing the "inaccessible" answer.

3. On each of the "Checklists," the Department structured the objective-format questions such that the answer indicating a product was more accessible was almost always "yes," while the answer indicating that a product likely contained barriers was usually "no." Each page of the Checklists accordingly stated, "Any 'no' answer may indicate a problem with accessibility." Some evaluators may have selected "not applicable" as a response, even when doing so was inappropriate, to avoid choosing the "inaccessible" answer.

4. As with many other features that would increase accessibility, nondisabled users do not need to be inconvenienced when IT office equipment provides an option for the user to "confirm" his or her choices before triggering an action. Instead, equipment can be designed with a toggle button, enabling someone who prefers to "confirm" his or her selections to do so. When the button is not activated, nondisabled users can operate the equipment in the standard fashion. For example, someone with significant cerebral palsy may wish to use a "confirmation" mode. She would first push a "confirm selections" toggle button to turn on this option, then push "print" (or whatever other function she wishes to activate), then "confirm" to print. If she inadvertently hit a button near the "print" button, she would keep trying to hit "print." Once she had successfully chosen the "print" button, simply hitting "confirm" would enable her to print.

5. Approximately 10% of the people who are blind use Braille. For people who are deaf and blind, however, a built-in Braille display may provide the only means of access to information that is not available in an electronic format (electronic format material is displayable in Braille through the use of assistive technology).

6. The Department did not require agencies to confine their accessibility testing exclusively to federal employees with disabilities. As many agencies have found, partnerships with disability advocacy groups have often been the source of creative, cost-effective solutions.


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