>Date: Sun, 09 Jun 2002 19:58:31 -0500
>From: Kelly Pierce <[log in to unmask]>
>Subject: Industry White Paper On ATM Access
>Sender: "* EASI: Equal Access to Software & Information"
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>ABA Banking Journal
>
>Saturday, June 01, 2002
>
>The Americans with Disabilities Act and Its Effect on Automated Teller
>Machines
>
>By Bill Jackson, CHIEF TECHNICAL OFFICER, TRITON
>
>INTRODUCTION
>
>The Americans with Disabilities Act (ADA) was first enacted in the United
>States in 1990. It covers a wide range of issues relating to the
>accessibility of goods and services by those with some type of
>disability. The US Government classifies approximately 43 million
>Americans with some type of disability. The most common disabilities are
>blindness (between 10 and 11 million Americans are legally blind, defined
>as: corrected vision of no greater than 20/200), and paralysis or other
>conditions that require the use of a wheelchair to get around.
>
>Automated Teller Machines were one of the first "products" singled out
>for specific regulation by the ADA guidelines. The regulations for ATMs
>became law in 1992 and have not changed much in 10 years. Today,
>technology has advanced well beyond what was available in 1992, so
>changes to the current rules are in the works.
>
>The Current State of the Regulations While the original text of the ADA
>guidelines would fill a good-sized binder, the parts specific to ATMs are
>focused and quite short. Unfortunately, one paragraph has sparked heated
>debate and subsequent lawsuits over its interpretation.
>
>This paper will discuss the state of the current guidelines in some
>detail. The entire text of the ATM section of the ADA is included in
>Appendix A for reference.
>
>There are two general areas of concern for ATM design. First,
>accessibility refers to the physical placement of the equipment and the
>ability of a disabled person to actually get to it to use it. The second
>concern is usability by visually impaired persons.
>
>Section 4.34.1 General Accessibility
>
>The installation of the ATM is generally controlled by the independent
>sales organization (ISO). Manufacturers have no responsibility for the
>final placement, but can ensure that their customers have the information
>necessary to comply with the installation guidelines. This section simply
>says that doorways and aisles must be a certain width to allow persons in
>wheelchairs to navigate up to the ATM.
>
>Section 4.34.2 Approaching the ATM, Clear Floor Space
>
>Once a wheelchair user gets to the ATM, there must be enough room to
>position the chair in a manner that will allow access to all necessary
>controls. The minimum amount of floor space needed is shown in the figure
>here.
>
>Section 4.34.3 Reach Ranges
>
>This section deals with the ability of a wheelchair user to reach the
>controls of the ATM, without having to reach beyond a comfortable or safe
>limit. The ATM owner can choose to comply with either the forward reach
>requirements or the side reach requirements. As shown in the drawing to
>the right, if approached from the forward position, the controls and
>delivery slots must generally be between 15" and 48" from the floor
>surface.
>
>When approached from the side (the most common approach) the reach ranges
>are somewhat wider. This is because the user does not have to reach out
>over the front and possibly fall out of the chair. The range here is
>between 9" and 54".
>
>Section 4.34.4 Controls
>
>This section ensures that all user controls, buttons, doors, etc. can be
>operated with less than five pounds of force.
>
>Section 4.34.5 Equipment for Persons with Vision Impairments
>
>This section has sparked most of the debate among ATM owners,
>manufacturers, and advocates for the visually impaired. In the early days
>of the ADA, ATM manufacturers and advocate groups for the blind agreed
>that Braille was the best method for instructing visually impaired people
>on how to use the ATM. For many years, Braille was used on ATM keypads
>and on auxiliary labels surrounding certain controls and slots.
>
>In the late 1990s, advocate groups for the blind began to work with
>certain banks and manufacturers to try to develop talking ATMs. The first
>talking ATM in the US was installed by a credit union in San Francisco
>City Hall in 1999. Many lawsuits have been filed based on the
>interpretation that section 4.34.5 required speech output from ATMs.
>While this has not actually been argued in court, since all cases have
>been settled, many banks are working toward installing talking ATMs
>before the changes that would clarify that speech is required are passed
>into law. Bank of America has been the leader in installed machines
>capable of speech, but several other large banks also are deploying
>speech-capable machines.
>
>The Proposed Changes to the Current ADA Laws
>
>A government-sponsored group, called the Access Board, is responsible for
>review of the current ADA guidelines and proposing changes where
>appropriate or needed. This group is made up of both government employees
>and representatives from the public sector, including representatives of
>disabled groups. Their web site can be found at www.access-board.gov.
>
>The Access Board published a proposed set of changes to the ADA laws in
>November of 1999. The changes affected every aspect of ADA, not just
>ATMs, but for the purposes of this white paper, we are concerned with
>only those rules that affect ATMs. The proposed changes were put out for
>public comment, and over 2,500 comments were received during the
>six-month public input period. Final recommendations are pending. Once
>the Access Board adopts the final guidelines, which is expected to occur
>this summer, the Department of Justice must adopt them as part of its ADA
>regulation before they have force of law.
>
>The proposed changes affect several areas: Access and Reach
>
>It is expected that the height and reach requirements will be changed so
>that the maximum height will be 48 inches rather than the current 54
>inches. The requirement for clear floor space remains the same.
>
>Keypads
>
>The most noteworthy proposal for keypads is the recommendation to use a
>telephone-style layout for the number keys. A single raised dot on the 5
>key would serve as a reference point. The proposed guidelines may
>recommend minimum spacing between keys, certain heights to the keys
>themselves and raised symbols on the function keys to allow blind and
>visually impaired people to feel the different keys. There will probably
>not be any recommendation for keys to be certain colors, as long as the
>keys, the text on them, and the background around the keys contrast with
>each other.
>
>Output of Information
>
>The change that has presented the greatest challenge for ATM
>manufacturers is the proposed requirement for speech capabilities. This
>section presents the greatest challenge for the ATM manufacturers as they
>bring their equipment into compliance. It is also the only area where
>technology really has had an impact.
>
>The proposed guidelines require audible instructions to be available,
>allowing a blind person to perform any transaction a sighted person would
>be able to perform using the ATM. Blind and visually impaired users can
>be accommodated in a different fashion, but access must be equal.
>
>This particular provision has caused many manufacturers a great deal of
>trouble, due to the flexibility required to be able to support it in its
>entirety. In addition to "speaking" the menu, the terminal must also be
>able to speak the following:
>
>* What the user has selected before the transaction is executed.
>
>* All transaction information on the receipt, including the ATM user's
>balance.
>
>* Instructions for use of the audio guidance portion of the terminal.
>
>Under the proposal, confirmation of the transaction before it is executed
>is simple and basic, and must allow the person to change or cancel the
>transaction if a mistake has been made on input. Reading the receipt
>allows a user to confirm that the transaction worked. Additionally,
>transaction information on the receipt would have to be presented orally.
>This would include the Reg. E information: amount, date, type of
>transfer, account identification, terminal location as well as balance
>information. However, it is expected that the final guidelines will not
>require, for example, the account number, the date and terminal location.
>
>Help must be provided for users who are not yet familiar with the
>operation of the terminal. This should include description of the
>location of the important user interface points (keypad description, card
>reader, printer, etc.), description of the function keys and the symbols
>on them, and how to perform simple tasks.
>
>Changes to ATM output are not limited to assisting the blind users. The
>Proposed guidelines also require simple san serif characters (this
>typestyle is san serif; this is not) of a certain minimum height that
>contrast with the background. This is to aid people who see poorly but
>can make out large type styles. People who are not visually impaired but
>cannot read the supported language can use the audio output. This group
>can include dyslexic, illiterate, barely literate and visitors or
>immigrants who may speak English but do not read the language.
>
>One saving grace in the proposed guidelines is that in locations with
>multiple ATMs, only one must provide speech capabilities. However, there
>is no definition of "location." For example, a bank may have several ATMs
>in a lobby area, and under the new guidelines only one would have to be
>able to talk. This is fairly clear. On the other hand, consider an indoor
>shopping mall, where there may be several ATMs throughout the general
>area, as well as some in the larger retail locations. The machines may be
>owned by different entities as well. In this example, it is not clear if
>the "one talking ATM" per location applies, and if it does, who is
>selected to bear the burden of providing the talking machines.
>
>The Players
>
>There are several organizations that are involved in the process of
>changing the ADA guidelines. Each group is listed here along with a brief
>description of who makes up the group and what their relationship is to
>the process.
>
>The Access Board
>
>The Access Board is a group of about 30 people, half of them government
>representatives from most of the federal departments, and the other half,
>members of the public. The public members are appointed by the President
>and serve four-year terms. The board came into existence in 1973.
>
>It's chartered with:
>
>* Developing and maintaining accessibility requirements for the built
>environment, transit vehicles, telecommunications equipment, and for
>electronic and information technology.
>
>* Providing technical assistance and training on these guidelines and
>standards.
>
>* Enforcing accessibility standards for federally funded facilities.
>
>The Access Board is currently reviewing public comments to its proposed
>changes to the guidelines. It is expected to finalize changes late this
>summer.
>
>The Department of Justice (DOJ)
>
>The DOJ is the government agency that is responsible for adopting the ADA
>regulations (which include the Access Board's guidelines) and for
>implementing and enforcing the ADA. The DOJ will not act on the proposed
>changes to the regulation until the Access Board finalizes changes to the
>guidelines.
>
>The Blind Industry Groups
>
>There are three major blind advocacy organizations that have been
>involved in the process of commenting on and shaping the proposed
>changes. They include:
>
>* The National Federation of the Blind.
>
>* The American Council for the Blind.
>
>* The American Federation of the Blind.
>
>Each of these groups has its own set of ideas on the proposed changes,
>which are sometimes not in complete alignment. In general, though, they
>each advocate greater accessibility to ATMs for the blind. These groups
>generally employ legal counsel to represent their interests and goals.
>
>The Industry Group
>
>An informal group organized by the American Bankers Association
>representing the ATM industry has formed to provide representation to the
>
>Access Board for the ATM industry. The Industry Group's mission is to
>ensure that whatever guidelines are adopted by the government are not
>only reasonable, practical and fair, but also useful to disabled people.
>This group is made up of the following types of organizations:
>
>* ATM manufacturers (all inclusive)
>
>* NCR
>
>* Diebold
>
>* Fujitsu
>
>* Triton
>
>* Banks (not all inclusive)
>
>* Bank of America
>
>* Bank One
>
>* PNC
>
>* Fleet Bank
>
>* Several other large and a few small banks
>
>* Independent service organization's (all inclusive)
>
>* E*Trade
>
>* Processors (all inclusive)
>
>* Concord EFS
>
>* Software vendors (all inclusive)
>
>* ACI
>
>* Industry trade group
>
>* American Banker's Association (ABA)
>
>Each of the group members represents their particular area of interest.
>
>The ABA, with the able guidance of Nessa Feddis, has been responsible for
>putting the Industry Group together and coordinating meetings with blind
>advocacy groups, educational organizations involved in accessibility and
>even the DOJ.
>
>The Industry Group chair is Bill Raymond, Senior Vice President for Bank
>of America.
>
>While some of the members of this group are competitors, they have
>managed to work together for the good of the industry. All members do not
>see eye-to-eye on all issues but agree that without input from the
>industry, the new guidelines could be quite onerous and expensive.
>
>The Timeline for the New Guidelines
>
>This section is a forecast of what is generally agreed to be the timeline
>for implementation of the new ADA changes. These are estimates.
>
>Step 1: The Access Board will privately approve and submit its final
>guidelines sometime in April of 2002, although the final proposal may not
>be publicly available until midsummer. Some minor changes in the current
>proposal are expected.
>
>Step 2: The Office of Management and Budget (OMB) will review the
>proposal to ensure it does not place an undue financial burden on any
>organization as a whole. Generally, the review does not take into account
>the burden, real or not, on individuals. The OMB should receive the
>Access Board proposal in March of 2002. The OMB has 60 (or possibly 90)
>days to review it.
>
>Step 3: The Department of Justice should receive the proposed guidelines
>with OMB comments in mid-2002. The DOJ can accept the Board's
>recommendations or modify them, but it is unlikely that it would modify
>them as it is on the Access Board. The DOJ will then put out for public
>comment its proposed changes to the regulation, along with the guidelines
>adopted by the Access Board, and will probably allow 60 to 90 days for
>comment. Once the review is completed, the DOJ will finalize the
>regulation. The DOJ activity on ADA changes has been scaled back due to
>the terrorist attacks of September 2001.
>
>Step 4: At the time of adoption, the DOJ can specify the phase-in time
>for the new regulations. The DOJ may allow as much as two years for
>manufacturers to comply with the talking requirements of the new rules.
>The regulation will address if, how, and when the changes apply to
>existing ATMs.
>
>The Installed Base
>
>The proposed rule changes will certainly affect all new ATMs installed
>after some as-yet undetermined cut-in date. However, it is not clear how
>the changes will apply to the installed base of equipment, estimated to
>reach in excess of 325,000 terminals by the end of 2001. The Department
>of Justice will make that determination.
>
>There has been much talk in the industry about upgrades. Many large banks
>are expecting to be required to upgrade and have already started the
>process. Their belief is centered on the idea that the current law could
>be interpreted to require some form of speech. Bank of America has openly
>committed to upgrading 7,000 of its ATMs by 2005. Bank of America has
>already upgraded several hundred existing terminals.
>
>While some banks are already pursuing upgrades, others are blissfully
>unaware of the impending changes and the spate of lawsuits. Most small,
>retail ATM owners are only just now learning of the ADA's impact on ATMs.
>Large retail owners are probably in the best position today. Some of
>these owners are already taking action, requiring their new installations
>to be speech-capable.
>
>As the new ADA guidelines are put into effect, it will take some time to
>determine what will happen with regard to the installed base. The
>expectation is that some of the existing terminals will have to be
>upgraded. Which ones will be affected is unclear. A large bank with
>presence in multiple states may have to upgrade at least one ATM in each
>location to talk, while some small convenience store owner with only one
>or two ATMs may not be affected. The life span of the ATM terminal also
>may play a role in the upgrade plan. If a terminal's design life is five
>years, it may be replaced before an upgrade will ever be required. If the
>design life is 20 years, however, then it may be affected.
>
>The Technology of Talking ATMs
>
>ATMs can be classified into two general categories of technology:
>
>* Terminals that have a personal computer as the central controller and
>run a commercially supported operating system, such as OS/2 or Windows,
>represent the high end of the market.
>
>* Terminals that do not have a PC as the main controller represent the
>low end of the market. These are most commonly referred to as embedded
>systems, which feature proprietary electronics and software that have
>been purpose-built for the product. These systems are typically less
>expensive than the PC-based terminals.
>
>Making an ATM talk is a task that can range from trivial to extremely
>difficult. On a high-end PC-based terminal, speech capability can be
>accomplished in two basic ways. Each method has advantages and
>disadvantages.
>
>The first and most commonly used method is to employ .WAV files. This is
>a specific file type supported by OS/2 or Windows that is the digital
>equivalent of a tape recording. When a .WAV file is "played" on the PC,
>it sounds like a pre-recorded voice.
>
>The advantages of .WAV files include:
>
>* They can be played on low-end PC's.
>
>* The quality of speech is very good. It can sound just like the human
>voice.
>
>* They can be played through the PC speaker and do not usually require a
>sound card.
>
>The disadvantages of .WAV files include:
>
>* .WAV files must be pre-recorded, most often from a human voice. This
>can prove challenging when changes are needed, adding difficulty to
>maintaining consistency in voice recording.
>
>* It is impractical to record all possible words or phrases that are
>needed to support the program.
>
>The second technology employed by high-end terminals is text-to-speech
>synthesis software, which turns text into speech.
>
>With text-to-speech software, the following advantages exist:
>
>* The software can translate and deliver verbally any word or phrase that
>can be put into text form, providing all of the flexibility needed to
>complete any type of self-service transaction.
>
>* There is no human talent required to record phrases.
>
>There are several disadvantages of text-to-speech synthesis software,
>which include:
>
>* It requires a much more powerful PC than .WAV files. Generally, a fast
>Pentium II or better processor is needed to adequately run the speech
>software without degrading the rest of the ATM application.
>
>* The synthetic voice does not sound human, although most people easily
>understand it.
>
>Many ATMs currently installed do not have the processing power to run
>text-to-speech synthesis software. For these, .WAV files are the only
>practical option. Only the newest generations of PC-based terminals from
>the major manufacturers have the processing power to run text-to-speech
>software.
>
>It is currently not practical to comply completely with the proposed ADA
>changes with .WAV files. Many banks offer the ability to "name" secondary
>accounts, such as "Vacation Account." Banks and their ATM systems that
>support Open Account Relationship (OAR), where users have access to all
>of their accounts, cannot anticipate all possible names for user
>accounts. With text-to-speech synthesis software, this is not a problem.
>The name of the account is simply fed into the software and it is spoken.
>
>For embedded system-ATMs, there are fewer choices. Typically, these
>systems cannot play .WAV files, nor do they have the ability to run
>text-to-speech synthesis software. To support speech capabilities, these
>devices must rely on additional hardware capabilities that can play
>prerecorded phrases of dedicated micro controller systems that are
>designed to convert text-into-speech. This approach can add greatly to
>the cost of these systems, which are typically designed for the low end
>of the marketplace.
>
>Web Sites of Interest
>
>Government
>
>* The Access Board www.access-board.gov
>
>* The Department of Justice www.usdoj.gov
>
>Blind Organizations
>
>* The National Federation of the Blind (NFB) www.nfb.org
>
>* The American Council for the Blind (ACB) www.acb.org
>
>Industry
>
>* The American Federation of the Blind (AFB) www.afb.org
>
>Industry
>
>* The American Bankers Association (ABA) www.aba.com
>
>Appendix A
>
>This section contains the complete text of the 1990 ADA regulations
>pertaining to ATMs.
>
>4.34 Automated Teller Machines.
>
>4.34.1 General. Each machine required to be accessible by 4.1.3 shall be
>on an accessible route and shall comply with 4.34.
>
>4.34.2 Clear Floor Space. The automated teller machine shall be located
>so that clear floor space complying with 4.2.4 is provided to allow a
>person using a wheelchair to make a forward approach, a parallel
>approach, or both, to the machine.
>
>4.34.3 Reach Ranges.
>
>(1) Forward Approach Only. If only a forward approach is possible,
>operable parts of all controls shall be placed within the forward reach
>range specified in 4.2.5.
>
>(2) Parallel Approach Only. If only a parallel approach is possible,
>operable parts of controls shall be placed as follows:
>
>(a) Reach Depth Not More Than 10 in (255 mm). Where the reach depth to
>the operable parts of all controls as measured from the vertical plane
>perpendicular to the edge of the unobstructed clear floor space at the
>farthest protrusion of the automated teller machine or surround is not
>more than 10 in (255 mm), the maximum height above the finished floor or
>grade shall be 54 in (1370 mm).
>
>b) Reach Depth More Than 10 in (255 mm). Where the reach depth to the
>operable parts of any control as measured from the vertical plane
>perpendicular to the edge of the unobstructed clear floor space at the
>farthest protrusion of the automated teller machine or surround is more
>than 10 in (255 mm), the maximum height above the finished floor or grade
>shall be as follows:
>
>Reach Depth
>
>Table with 2 columns and 10 rows
>
>inches millimeters
>
>10 255
>
>11 280
>
>12 305
>
>13 330
>
>14 355
>
>15 380
>
>16 405 table end
>
>Table with 2 columns and 8 rows
>
>17 430
>
>18 455
>
>19 485
>
>20 510
>
>21 535
>
>22 560
>
>23 585
>
>24 610 table end
>
>Maximum Height
>
>Table with 2 columns and 10 rows
>
>inches millimeters
>
>54 1370
>
>53 1/2 1360
>
>53 1345
>
>52 1/2 1335
>
>51 1/2 1310
>
>51 1295
>
>50 1/2 1285 table end
>
>Table with 2 columns and 8 rows
>
>50 1270
>
>49 1/2 1255
>
>49 1245
>
>48 1/2 1230
>
>47 1/2 1205
>
>47 1195
>
>46 1/2 1180
>
>46 1170 table end
>
>(3) Forward and Parallel Approach. If both a forward and parallel
>approach are possible, operable parts of controls shall be placed within
>at least one of the reach ranges in paragraphs (1) or (2) of this
>section.
>
>(4) Bins. Where bins are provided for envelopes, waste paper, or other
>purposes, at least one of each type provided shall comply with the
>applicable reach ranges in paragraph (1), (2), or (3) of this section.
>
>EXCEPTION: Where a function can be performed in a substantially
>equivalent manner by using an alternate control, only one of the controls
>needed to perform that function is required to comply with this section.
>If the controls are identified by tactile markings, such markings shall
>be provided on both controls.
>
>4.34.4 Controls. Controls for user activation shall comply with 4.27.4.
>
>4.34.5 Equipment for Persons with Vision Impairments. Instructions and
>all information for use shall be made accessible to and independently
>usable by persons with vision impairments.


                 Norman Coombs, Ph.D.
CEO, EASI (Equal Access to Software and Information)
http://www.rit.edu/~easi
Professor Emeritus, Rochester Institute of Technology
E-mail: [log in to unmask]
         Cell (949) 922-5992
http://www.rit.edu/~nrcgsh
22196 Caminito Tasquillo
Laguna Hills CA 92653