The information contained herein is subject to change without notice. HP processes may vary. The only
warranties for HP products and services are set forth in the express warranty statements accompanying such
products and services. Nothing herein should be construed as constituting an additional warranty. HP shall not
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401 General ................................................................................................................................................................. 14
402.2.3 Speech Delivery Type and Coordination .......................................................................................... 16
402.2.4 User Control ......................................................................................................................................... 16
403.1 General ......................................................................................................................................................... 21
404 Preservation of Information Provided for Accessibility ............................................................................... 22
404.1 General ......................................................................................................................................................... 22
406 Standard Connections ....................................................................................................................................... 23
406.1 General ......................................................................................................................................................... 23
407 Operable Parts .................................................................................................................................................... 24
407.1 General ......................................................................................................................................................... 24
407.8.2 Side Reach ............................................................................................................................................ 35
408.1 General ......................................................................................................................................................... 41
409 Status Indicators ................................................................................................................................................ 42
409.1 General ......................................................................................................................................................... 43
410 Color Coding ........................................................................................................................................................ 44
410.1 General ......................................................................................................................................................... 44
411.1 General ......................................................................................................................................................... 45
412 ICT with Two-Way Voice Communication ...................................................................................................... 46
412.2 Volume Gain ................................................................................................................................................ 46
412.2.1 Volume Gain for Wireline Telephones ............................................................................................. 46
412.2.2 Volume Gain for Non-Wireline ICT .................................................................................................... 46
412.3 Interference Reduction and Magnetic Coupling .................................................................................... 47
412.4 Digital Encoding of Speech ........................................................................................................................ 48
412.5 Real-Time Text Functionality ................................................................................................................... 49
412.6 Caller ID ........................................................................................................................................................ 50
412.7 Video Communication ................................................................................................................................ 50
412.8 Legacy TTY Support ................................................................................................................................... 51
412.8.3 Signal Compatibility ............................................................................................................................ 51
412.8.4 Voice Mail and Other Messaging Systems ...................................................................................... 51
413.1 General ......................................................................................................................................................... 52
413.1.1 Decoding and Display of Closed Captions ....................................................................................... 52
413.1.2 Pass Through of Closed Caption Data ............................................................................................. 52
414.1 General ......................................................................................................................................................... 52
414.1.1 Digital Television Tuners .................................................................................................................... 52
414.1.2 Other ICT ............................................................................................................................................... 53
415 User Controls for Captions and Audio Descriptions ..................................................................................... 53
415. 1 General ........................................................................................................................................................ 53
Flashing – maximum allowable flashing content ........................................................................ 42
Color Coding ....................................................................................................................................... 44
Color coding – failing example ........................................................................................................ 45
As many businesses shift to a focus on accessibility web standards for their websites, online storefronts, and
software applications, hardware testing could continue to become increasingly less common. And yet, the
community of people with disabilities relies on hardware standards for much of their critical work,
communication, and personal technology needs. Many HP customers rightfully consider accessibility an
important factor in making an informed purchasing decision. Integral to our mission to empower everyone,
everywhere with the benefits of technology is our commitment to making HP products and services easier to
access and simpler to use for people with disabilities and age-related limitations. Therefore, our business and
reputation rely on transparent, repeatable, and accurate accessibility testing and reporting.
Performing a quality test necessitates both a command of product-level detail and comprehensive insight into
the worldwide regulatory landscape including U.S. Revised Section 508 at minimum and additional world
standards such as E.U. EN 301 549, U.S. ADA Accessibility Guidelines [ADAAG], and W3C WCAG 2.x. Our company
has a dedicated team of professionals in theHP Office of Aging & Accessibility
businesses to ensure we produce consistent, high-quality tests for HP accessibility conformance reports (i.e.
ACRs, VPATs).
Hardware ICT (information and communications technology) includes any part of a product that you can
physically touch, pick up, hold, and/or move around a room. Hardware is any physical parts that compose the
device (i.e. computer, printer, virtual reality headset, display, etc.). The hardware in scope for accessibility
testing may be as simple as a monitor with no physical controls or as complicated as a multifunction printer
with an integrated screen and keyboard, multiple paper trays, and additional accessories (e.g. HP LaserJet
Enterprise M528).
Testers must look at their work from the perspective of the end user, keeping in mind that user experiences
vary. Disability is diverse and individual, and may be temporary, acquired, or lifelong. Two individuals with the
“same type” of disability—whether it be visual, auditory, physical, or cognitive—have different needs and
preferences. As you systematically test the hardware, craft your remarks and explanations, and take careful
test notes.
A quality accessibility test does not necessitate a comprehensive understanding of a hardware product’s total
functionality. If specific questions arise during the test process, consult a technical reference from the HP
Business Unit or other expert sources (e.g. a user guide, technical manual, etc.).
A quality accessibility test does paint a vivid picture of how people with disabilities interact with particular ICT
(information and communications technology) in test. At the forefront of your thoughts should be the common,
everyday experiences that real people in real situations have with the hardware. Ask yourself: Can the device be
positioned and configured such that someone with a mobility limitation has a frictionless customer experience?
Do tactile indicators on buttons enable an individual with low vision to effortlessly turn on the product?Include
any insights that convey useful information about accessibility defects, workarounds, and/or limitations; they
prove useful when reading the test results.
The results should be reported to the HP Business Unit that created the product with two goals in mind: 1)
Accessibility remediation, and 2) Documentation of incremental progress through this evaluation process and
across product lifecycles in general.
Finally, the significance of clarity in all testing protocols cannot be underemphasized. In your notes, precisely
record what is tested, including: Official name, code name, version, date tested, technical lead giving
information, firmware, software, documentation, and any video support. Notes and test results need to allow
another accessibility tester to have repeatable results.
Articulate the limitations and consistent rules that dictated what you placed in the hardware versus software
chapters respectively. Clear communication will facilitate reproducible testing.
Scrutinize all aspects of the device when determining what HP considers “in scope” for an accessibility
hardware test. First, determine which parts of the product are hardware, firmware, software, or added ICT.
Then, carefully record this classification in the test protocol such that the results correspond with the correct
success criteria. Do not record software results in the hardware chapter of any test record. When followed
correctly, this procedure guarantees documentation of precisely “what was tested” so no confusion arises as
we keep reinventing our hardware.
Software can be anything from an integrated, installed operating system (e.g. Microsoft Windows) to a mobile
device application used to operate the hardware. Each essential piece of software—whether web-based or
locally-installed—must be tested. Similar to hardware evaluation pay attention to the software version, as
changes occur independently of hardware upgrades.
Firmware built into the hardware and present in a closed functionality environment (e.g. a printer) should be
named with version number and tested with the hardware. Record these results in the hardware chapter; in
your remarks, explicitly differentiate when the test was firmware-centric versus hardware-centric. Significant
changes can occur between versions so details matter. Mistakenly testing an incorrect firmware version could
change the test results, thereby yielding outdated and/or misleading information to our customers.
Conscientiousness is key.
When assessing a new piece of equipment for a test, the initial and successive visual inspections are critical:
•Document in writing and photos all technical information about the hardware. Many products
belonging to the same “series” or “family” share similar characteristics. Make known exactly
what was tested and the results of that test; this clarity will save headaches later when
analyzing the results.
•Know the primary use case of the product (a thin client device can resemble a notebook PC
yet have different functionality)
• Is there software that needs testing separately?
• Examine all ports, plugs, and inputs
• Check color contrast on the hardware itself, including labels
• Open latches, doors, covers, and bins
• Does the device have a touch screen or other screen?
• Examine keyboard, on/off buttons, other buttons, and tactile indicators
• Assess primary and secondary use of the hardware
• Is it large or smaller—and do height and reach requirements apply?
• What functionality is normal, everyday use?
• Are maintenance items part of a user’s experience?
• Is color or lights the only method of visual information to user?
• What is the first-time use / out-of-box-experience?
• What is the signup, login, and/or registration experience, if such is required to use the
hardware?
•In any printed materials included with the hardware, is equivalent information easily
discoverable in an accessible digital / online format also?
• Is contact information for support easily discoverable in an accessible format?
• Are there any glaring accessibility concerns?
At the beginning of the test, photograph and write down anything noteworthy. Ask technical questions early
and often during the process. Seek feedback from the HP Business Unit as you go, sharing your observations,
questions, and/or concerns about accessibility in particular and the user experience in general.
Use testing tools to correctly identify the hardware’s conformance to standards, including:
• Digital Camera
• Force meter
• Tape measure
• User Manual or Technical Specifications Manual
• Access to system components during testing, when needed
Common software testing tools
•JAWS
o Screen reader for Microsoft Windows (demo version available)
•NVDA
o Free, open-source, portable screen reader for Microsoft Windows (recommended)
•VoiceOver
o Built-in screen reader for Apple products
• W3C Nu markup HTML conformance checker
• Microsoft Windows Ease of Access Magnifier
• Microsoft Windows Ease of Access Color Contrast
• Microsoft Inspect Objects
• Accessibility Insights
• WAVE Toolbar
• The Web Accessibility Toolbar
o Free add-on for Internet Explorer
• The Color Contrast Analyzer
o Free desktop application for Windows and Mac
• ANDI
o U.S. federal government tool on Github
Note on testing tools
Preferred testing tools can change rapidly. Many are excellent and behave similarly. Any tools used during
testing should be documented so the reader understands with what tools the test was performed.
Testing and reporting have a close relationship and serve many functions for HP, including meeting critical
customer requirements for sales opportunities and lending insight into how we can make our products more
valuable to everyone, everywhere. For many procurement opportunities, we submit an Accessibility
Conformance Report (ACR) following the ITI VPAT template. The accessibility testing completed for this ACR
creates a valuable feedback loop with the HP Business Unit and can strengthen the case for more accessibility
improvements in future product development. When we address known accessibility defects, it improves the
product experience for all our customers.
All test evaluations and ACRs must be:
• Objective and unbiased
• Conducted by following a published and repeatable evaluation process
• Documented with accurate and detailed remarks
By statute, the scope of U.S. Revised Section 508 encompasses all of the U.S. federal government. A majority of
U.S. states and many publicly-funded entities (e.g. state government agencies, public schools, etc.) have
adopted the U.S. Revised Section 508 standard as a mandatory procurement requirement.
private organizations have voluntary adopted the standard as a customer requirement, though they have no
legal obligation to do so. HP continues to experience an increase in requests for ACRs from our customers.
1
In addition, some
A quality ACR sets clear expectations about the accessibility of a product, including the defects, by outlining the
test results with detailed remarks. As a company, it is vital that we accurately test according to a published test
process and report the results in unbiased, technical language. This transparency best positions the customer
to make an informed purchasing decision.
As you follow the HP Accessibility Test Plan, define what accessibility criteria in test “does not support” and
illustrate what happens with the product in question. Leave no room for confusion. When testing and reporting
the results, all relevant information to a person with a disability must be communicated. This granularity makes
for transparent, accurate reports that inspire confidence and trust in the report’s consumer.
1
Navigating VPAT 2.0: A Guide for Vendors, Level Access – Available at: https://www.levelaccess.com/navigating-vpat-2-a-guide-for-
Ensure the tester defines the scope for this test process and documents it so that it can be understood and
duplicated by another tester and compared to a user need or use case. Documenting during the testing both in
written and picture format is invaluable.
401.1 Scope
The requirements of Chapter 4 shall apply to ICT that is hardware where required by 508 Chapter 2 (Scoping
Requirements), 255 Chapter 2 (Scoping Requirements), and where otherwise referenced in any other chapter of
the Revised 508 Standards or Revised 255 Guidelines. Revised Section 508 defines hardware as “a tangible
device, equipment, or physical component of ICT.”
Hardware that is assistive technology shall not be required to conform to the requirements of this chapter.
Examples of hardware that are not required to conform to the requirements of this chapter include hearing
aids, refreshable braille displays, trackball and joystick mouse, sip and puff technology, etc.
402 Closed Functionality
Where ICT has closed functionality, that closed functionality shall be operable without requiring the user to
attach, connect or install assistive technology. Personal headsets and induction loops shall not be classed as
assistive technology for the purpose of this clause.
Automated teller machines (ATMs) are an example of closed functionality ICT. Any individual using the ATM
should be able to fully access the machine without needing to alter the machine in any way. Users who cannot
read or have trouble reading text on the machine can have the text read out loud but may need to use a
personal headset to trigger the text to speech mechanism of the machine.
Closed Functionality can be very individualized to each product and use of the product. Some items which may
allow for peripherals and other software or accessories to be plugged in can operate both as open and closed.
This can be noted in the remarks and test notes as the hardware is tested. There are many reasons and
situations and security concerns which can create a closed functionality condition in testing.
402.2 Speech-Output Enabled
ICT with a display screen shall be speech-output enabled for full and complete use. Operating instructions and
orientation, visible transaction prompts, user input verification, error messages, and all displayed information
for full use shall be accessible to, and independently usable by, individuals with vision impairments. Speech
output shall be delivered through a mechanism that is readily available to all users, including, but not limited to,
2
Revised Section 508 Requirements. Available at: https://www.access-board.gov/guidelines-and-standards/communications-and-
an industry standard connector or a telephone handset. Speech shall be recorded or digitized human or
synthesized. Speech output shall be coordinated with information displayed on the screen.
Speech output is not required for advertisements and other similar information unless they convey information
that can be used for the transaction being conducted. Likewise, audible tones shall be permitted instead of
speech output where the content of user input is not displayed as entered for security purposes.
Specific ICT can be exempted from meeting 402.2. Variable message signs conforming to 402.5 shall not be
required to be speech-output enabled. Likewise, speech output shall not be required where ICT display screens
only provide status indicators and those indicators conform to 409. In another instance, ICT shall be permitted
to conform to 409 in lieu of 402.2 where speech output cannot be supported due to constraints in available
memory or processor capability. Lastly, speech output shall not be required for: the machine location; date and
time of transaction; customer account number; and the machine identifier or label.
This speech enablement must be in the firmware. If this is enabled because of added assistive technology or a
software operating system or application. The test results are recorded in the software chapter. This is
essential as software can vary from hardware product and needs to be separated for user clarity and
understanding of essential functionality.
Examples of hardware with speech output are kiosks, printers, atm.
402.2.1 Information Displayed On-screen
Speech output shall be provided for all information displayed on-screen.
ICT with a display screen shall be speech-output enabled. Operating instructions and orientation, visible
transaction prompts, user input verification, error messages, and all displayed information for full use shall be
accessible to, and independently usable by, individuals with vision impairments. Speech output shall be
delivered through a mechanism that is readily available to all users, including, but not limited to, an industry
standard connector
Speech output shall be coordinated with information displayed on the screen.
Speech output is not limited to just textual elements on the screen but must also provide auditory information
about the user interface elements and states. Text fields, dropdown menus, checkboxes, images, buttons, and
other user interface elements when applicable. Information about the states of user interface elements such as
required fields, values of those fields.
Speech output is not required for advertisements and other similar information unless they convey information
that can be used for the transaction being conducted. Likewise, audible tones shall be permitted instead of
speech output where the content of user input is not displayed as entered for security purposes.
Test Procedure:
1. Cover the screen(s) for the device under test and attempt to perform the same basic user scenarios as
outlined in the main test specification(s) for the product. For example, for self-contained singlepurpose retail point of sale kiosk (i.e. a cash register which is not simply a tablet or desktop computer
with point of sale software), cover the main screen and perform all the basic functionality testing for
identifying items, applying discounts, totaling final cost, accepting payment, etc.
3
or a telephone handset. Speech shall be recorded or digitized human or synthesized.
This speech enablement must be in the firmware. If this is enabled because of added assistive technology or a
software operating system or application. The test results are recorded in the software chapter. This is
essential as software can vary from hardware product and needs to be separated for user clarity and
understanding of essential functionality.
3
Industry standard connectors include but not limited to 3.5 mm audio jack, USB, RJ-45, and RJ-11.
Where transactional outputs are provided, the speech output shall audibly provide all information necessary to
verify a transaction.
Where ICT is closed to visual access and provides receipts, tickets, or other outputs as a result of a self-service
transaction, speech output shall be provided which shall include all information necessary to complete or verify
the transaction. In the case of ticketing machines, printed copies of itineraries and maps shall not be required to
be audible.
Transactions can be a purchase with or without a receipt printed (may email or text a ticket), any interaction
where there is a business deal. The user experience could be buying a ticket, pumping gasoline, interacting with
their banking kiosk, parking in a city, purchasing a lease on a bicycle, riding a ferry, or a self-checkout system of
any kind. A sale is considered a transaction.
Test procedure:
1. Ensure that speech output provides all information necessary to verify the transaction.
402.2.3 Speech Delivery Type and Coordination
Speech output shall be delivered through a mechanism that is readily available to all users, including, but not
limited to, an industry standard connector or a telephone handset. Speech shall be recorded or digitized human
or synthesized. Speech output shall be coordinated with information displayed on the screen.
Where speech output is provided as non-visual access to closed functionality, speech output shall be in the
same human language as the displayed content provided, except for proper names, technical terms, words of
indeterminate language, and words or phrases that have become part of the vernacular of the immediately
surrounding text; where the content is generated externally and not under the control of the ICT vendor, this
requirement shall not be required to apply for languages not supported by the ICT’s speech synthesizer; for
displayed languages that cannot be selected using non-visual access; where the user explicitly selects a speech
language that is different from the language of the displayed content.
To test for this requirement, ensure that the system provides speech output in a way that is available to all
users, such as an industry standard connector or a telephone handset, and ensure that speech output from the
system matches all displayed content on any view screens, touchscreens, or other mode of visual output.
All ATMs are required to contain an industry standard audio headphone jack. When a user plugs in headphones
to the 3.5 mm headphone jack on the ATM, the speech output will start. The audio produced shall match the
information displayed on the screen.
This speech enablement must be in the firmware. If this is enabled because of added assistive technology or a
software operating system or application, the test results are recorded in the software chapter. This is essential
as software can vary from hardware product and needs to be separated for user clarity and understanding of
essential functionality.
Test procedure:
1. Ensure that the system provides speech output in a way that is available to all users, such as an
industry standard connector or a telephone handset.
2. Ensure that speech output from the system matches all displayed content on any view screens,
touchscreens or other mode of visual output.
402.2.4 User Control
Speech output for any single function shall be automatically interrupted when a transaction is selected. Speech
output shall be capable of being repeated, interrupted, and paused. Exception: Where permitted by security
requirements under EN301-549.
This requirement can be met in part by ensuring that any presentation of options via audio provides an option
to repeat the entire list after the list has been announced to the user. This may look like, “select number 8 to
repeat the options.” Interruption of speech output should be available through a standard element such as a
“cancel” button. Interruption of speech could also be a natural side effect of selecting an option to continue or
cancel.
To test this requirement, verify that hardware provides a means of pausing or repeating speech output, and
verify that speech output is interrupted when a transaction is selected by the user.
Test procedure:
1. Verify that hardware provides a means of pausing or repeating speech output.
2. Verify that speech output is interrupted when a transaction is selected by the user.
402.2.5 Braille Instructions
Where speech output is required by 402.2, braille instructions for initiating the speech mode of operation shall
be provided. Braille shall be contracted
4
and shall conform too. However, devices for personal use shall not be
required to conform to 402.2.5. When a device can be a personal device and shared use device the personal use
exemption does not apply.
Where ICT is designed for shared use and speech output is available, a tactile indication of the means to initiate
the speech mode of operation shall be provided. The tactile indication could include Braille instructions.
To test for this requirement, ensure that braille instructions are provided that would allow the user to initiate
speech output without any visual information.
ATMs follow this guideline. Near the headphone jack of the machine, there will be a braille label to tell the user
where the headphone jack is located as well as a braille description of how to initiate the speech mode.
If the Braille Instructions were all in one area as a sign apart from the kiosk, this technically meets the
standards but is in no way accessible for a Braille user and does not meet HPs usability standards and should
4
Braille that is Unified English Braille (UEB) code meets contract braille requirement.
be documented. When accessibility testing, to be technically correct and not meet HP usability standards it is
not accessible. It is imperative to document these defects so that that the customer is informed, and the
product team can prepare a fix.
Test procedure:
1. Ensure that braille instructions are provided that would allow the user to initiate speech output
without any visual information.
402.3 Volume
Where sound, including speech output is provided, it shall provide volume control and output amplification
conforming to relevant 402 rules. ICT conforming to 412.2 shall not be required to conform to 402.3.
402.3.1 Private Listening
Where ICT provides private listening, it shall provide a mode of operation for controlling the volume. Where ICT
delivers output by an audio transducer typically held up to the ear, a means for effective magnetic wireless
coupling to hearing technologies shall be provided.
A handset that is hearing aid compatible and has a volume control would meet the requirements of this section.
To test for this requirement, ensure that a method is provided for adjusting the volume, and ensure that
hardware has a method for wirelessly connecting to listening devices.
A telephone is an example of hardware that is to conform to this requirement. Individuals using hearing aids
may find it difficult to use the telephone since the microphone in their hearing aid picking up sound is located
behind the ear. By including telecoils in hearing technologies, telephone receivers can magnetically couple with
the hearing technology so that the telephone receiver can send sound information to the hearing technology
allowing users to effectively hear the telephone conversation. A volume control must be included in the
telephone so that the user has the ability to change the volume to a level that suits them.
Test procedure:
1. Ensure that a method is provided for adjusting the volume.
2. Ensure that hardware has a method for wirelessly connecting to listening devices.
402.3.2 Non-private Listening
Where ICT provides non-private listening, incremental volume control shall be provided with output
amplification up to a level of at least 65 decibels (dB). A function shall be provided to automatically reset the
volume to the default level after every use.
Where auditory output is provided in closed functionality and is delivered through speakers on ICT, incremental
volume control shall be provided with output amplification up to a level of at least 65 dB. A function shall be
provided to automatically reset the volume to the default level after every use. For EN 301 549, this
requirement does not apply if speech is provided as non-visual access to ICT.
Test procedure:
1. To ensure the audio circuits have the required gain, some modification of the ICT may be required to
obtain access to testing points. Connect an audio test signal set at 1 KHz reference at 0 dB to the audio
input (I.e. HP 209A Audio Oscillator). The audio input connection is generally after the audio has been
decoded from the incoming signal or an equivalent signal that is an output of an internal facility,
feature or function within the ICT (I.e. output from an answering machine, output from a text to voice
decoder, etc.). Typically, the audio architecture of the ICT can rapidly identify this connection point.
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