This appeared in the February, 2001 publication of the American Banker's
Association.  Industry is helping spread the word about talking ATM's to
the many banks and atm owners that soon might be faced with this concern.

kelly


ATMS and Blind Users' Access

In recent years, ATMs have been one of the focal points for blind
representatives pressing for compliance with ADAAG.  There are several
reasons ATMs are a target.  An obvious one is that ATMs offer a basic and
convenient access to vital products - bank accounts.  Convenient access to
bank services, especially cash withdrawal, is a critical service and blind
customers have complained of the indignity - and security risks -
associated with asking a perfect stranger to withdraw cash from their
account at an ATM.

ATMs are also a target because of their ubiquity.  Blind groups feel that
just as curb cuts constantly remind the public of the needs of wheelchair
users, so will ATM features that assist blind users sensitize the public
to the needs of the blind community.  ATMs are particularly important
because they not only remind people of the general needs of blind people
but in particular of their needs with regard to technologically advanced
products.

Blind people are often frustrated by technological advances that actually
diminish their ability to use even simple products such as digital
thermostats or digital oven settings, let alone sophisticated facilities
such as the Internet.  Their belief is that the increased sensitivity to
their needs derived from the blind user features on ATMs will transfer to
other unrelated products.  Developers will then design new products with
their needs in mind and avoid the more expensive retrofitting.
Accordingly, a visible, omnipresent facility such as the ATM is important
in a much broader sense than simple access to banking services.

        For these reasons, in recent years, blind representatives have
been approaching ATM owners about improving blind users' access to ATMs,
relying on the 1992 ADAAG requirement that ATMs be "accessible to and
independently usable by persons with vision impairments." With some
exceptions, ADA is generally enforced through private lawsuits.
Solutions have varied as technology has improved and presented better
solutions.

When ADAAG first went into effect in 1992, as a practical matter, Braille
templates offered the only assistance to blind ATM users: ATMs that
verified user input or provided voice response were simply unavailable for
a shared ATM network environment. Today, however, that is changing.

Blind representatives are now demanding that ATMs provide audio output in
some fashion.  They argue that Braille instructions are insufficient:
first, they provide only cursory instructions that cannot guide users
through a transaction, and second, only a relatively small percentage of
blind people read Braille.

Moreover, voice is now technologically feasible.  Indeed, a number of
banks today have installed "talking" ATMs and other audio-assistance
features. (Headsets or phones carried by the blind users ensure privacy.)
In addition, the Access Board in November 1999 proposed to amend ADAAG to
specifically require audible "verification of user input," displayed text
and labels, as well as receipts.  The Access Board is expected to finalize
changes to ADAAG this year.

        That is not to say that there are not significant challenges and
costs associated with providing voice on ATMs. "Voice echo" that states
the function or number associated with a particular key is relatively easy
as that information is available locally at the ATM. The biggest challenge
has been to provide in audible format "dynamic" information, that is,
information coming from the host.  This includes, for example, balance
information, error messages, third party names, and account nicknames.
Even if it is technically feasible to present such dynamic information in
an audible format, cost may be significant. In addition to the ATM
hardware, there are expenses associated with ATM software, both at the
local, host, and network levels. However, technology in any given month
advances so that a workable and practical solution may resolve these
issues in the near future.

        Making new ATMs accessible may be the easier challenge. In many
ways, how and whether to make existing ATMs accessible raises greater
concerns and questions. Retrofitting existing ATMs can be much more
expensive, particularly given the manual labor.  In addition, older models
may not be able to be retrofitted.

Furthermore, it is not clear how the current regulation applies to existing ATMs or how any modified new regulation would apply to existing ATMs. The general rule under ADA is that facilities existing in 1992 only had to remove barriers if it was "readily achievable" and provide auxiliary aids and services if it was not an "undue burden."  However, facilities installed subsequently generally have to comply with ADAAG. It is not clear how this should be applied in the ATM environment.

When ADAAG went into effect in 1992, it was not possible to purchase and
install an ATM that provided audible text. Presumably and logically, then,
it could not have been required.

Some plaintiff's lawyers assert, however, that voice was required for all
ATMs installed after 1992 - or at least to those installed after audio
output technology became available -- under the current "independently
usable" standard.  Therefore, they argue, any ATM installed after 1992, or
when technology became available, must be retrofitted or replaced to
provide audio output.  Blind representatives argue for broad and strict
coverage to existing ATMs because they fear that otherwise, given the
saturated ATM market, applying it only prospectively will mean far fewer
ATMs will be accessible.  Blind representatives have used these arguments
to persuade some banks to develop schedules to install and retrofit ATMs
so that they are accessible to blind users.

There is also confusion about how any new specifications adopted by ADAAG
and the Department of Justice would apply to existing ATMs.  At the very
least, if an ATM provided some audio output prior to the adoption of any
new regulations, the ATM owner should only have to retrofit if is "readily
achievable" or not an "undue burden."  Banks are looking for relief with
regard to application of the new standard to existing ATMs given the
potential cost.

        ABA has been actively involved in this issue. It submitted
comments to the Access Board on its 1999 proposal and testified at the
Access Board's hearings.  In addition, it has attempted to bring together
the various interested parties, including ATM owners, vendors, networks,
software vendors as well as blind representatives, to work on a technical
as well as legal solution.  The first meeting was held in January 2001.
The next meeting is scheduled for early March.  The purpose is to try to
reach a consensus on a final regulation that the Access Board can consider
in its deliberations.

        Banks in the meantime should seriously investigate how they can
make ATMs more accessible to blind users.  The best place to start is with
blind customers and representatives.  They are the best source in helping
to understand blind users' needs and to devise an appropriate solution.
Moreover, a bank is less likely to be a target for a lawsuit if it has in
good faith tried working with blind groups and customers and then
developed and implemented a plan to ensure that blind people have the best
possible access to such a vital service. Banks should also contact their
ATM vendors and third party processors, if applicable. They will have the
technical advice to develop and implement any plan.


VICUG-L is the Visually Impaired Computer User Group List.
To join or leave the list, send a message to
[log in to unmask]  In the body of the message, simply type
"subscribe vicug-l" or "unsubscribe vicug-l" without the quotations.
 VICUG-L is archived on the World Wide Web at
http://maelstrom.stjohns.edu/archives/vicug-l.html