ONE phone design that meets all of the FCC proposed access requirements

(Trace Center Reference Design 1)

Reference Design IllustrationD

  • Infrared (IR) Port
    Allows wireless connection to assistive technologies

    Mass market appeal: Wireless connection to computer (modem)


  • Volume range
    Meets FCC specifications for those who are hard of hearing (phone is hearing aid compatible)

    Mass market appeal: Use phone in noisy environments (crowds, subway, airport, etc.)


  • Speakerphone function (optional)
    Facilitates use by people who have difficulty handling the phone

    Mass market appeal: Hands free or car use


  • Matrix display
    Allows use of graphics and multiline text messages including TTY conversations

    Mass market appeal: Text messaging or paging


  • Headset jack
    Allows connection of neckloops, silhouettes, Assistive Listening Devices, TTY's and headsets

    Mass market appeal: Headsets, hands free or car use


  • EZ button
    The EZ button allows you to have the label for any key read to you as well as the contents of the display and all menus and features of the phone.( Useful if you cannot see well, are blind, or if you have trouble reading the text on the phone for any reason.) Spoken words are displayed on screen in large type as well.

    Mass market appeal: Read small, seldom used labels without reading glasses. Read message or page while driving.


  • Easy to feel keys
    A nib on the 5 key and a ridge above and below the number keys makes eyes-free dialing easy. (Because of keypad edges, all keys are tactiley different.) Keys are dished as well to make it easy to use a mouthstick or other device to dial.

    Mass market appeal: Dial without looking at the keyboard


  • Connector
    No more fumbling with connector - it can be positioned and inserted purely by touch. You can also connect a keyboard to make programming easier or to send faster text (and TTY) messages. (Keypad on phone can also be used to type text messages.)

    Mass market appeal: Easier to correctly connect charger and accessories. Optional keyboard makes typing of longer messages easier. (e.g. hotel room email)


How this design addresses each of the FCC Guidelines

Subpart C -- Requirements for accessibility and usability

Sec. 1193.41 Input, control, and mechanical functions

FCC Guideline Guidelines Met? How the requirements are met. Cost & Ease of Implementation (If a company had been doing this as a matter of course. e.g. does not include cost of acquainting engineers with access.)

(a) Operable without vision.


Tactile keys and landmarks
All input and functions accessible via voice output

- All needed electronics for digitized speech already in today's digital phones; Need only small additions to software and sometimes additional memory (~100k) which will cost little in phones tomorrow. Memory is already available today in many phones (used for digital voice recording). - (This reference design uses spelled speech for transmitted text - voice synthesis will be possible in near future but is not quite practical today for inexpensive phones. Voice synthesis using network facilities is practical today - but is not proposed here.)

(b) Operable with low vision and limited or no hearing.


-Matrix Display - the labels of all buttons can be shown in large print prior to activating them.

Many newer cell phones already use matrix displays. Many have large print displays as standard or as a user setting.

(c) Operable with little or no color perception.


All color coded buttons and indicator lights distinguishable by other means (shape, label)

- Not a problem in most phones today. Any use of color just has to also be accompanied with a text label - as is true on all phone keys today.

(d) Operable without hearing.


Vibration ringer alert. Also buttons have tactile feel of activation (i.e. do not rely on auditory beeps). Visual indication of line status.

- Vibrator is standard in many cell phones. (Not in lower cost phones mostly due to marketing rather than cost.) Visual indication of line status is software only.

(e) Operable with limited manual dexterity.


EZ Access* - buttons can be selected in 2 steps - press desired button then confirm with EZ Button; Dished keys easy to press; Also optional 1-Button mode ; Connection of customized external keyboard.

- Software only for confirm and 1 button access features. (Less than 2k memory.)
- Dished keys is no cost, just a different key shape. - Keyboard connection can be via Infra-red or the connector on bottom (Based on industry standard ANSI/TIA/EIA-688)

(f) Operable with limited reach and strength.


Buttons easy to press down; One button mode.
Optional Speakerphone is easier for people who cannot place phone to ear; Optional Voice Dialing is faster for some.

- Light button pressure is standard on many phones. Optional speakerphone and voice dialing features are increasingly common - and cost for these features is dropping precipitously. (Speakerphone and voice dialing not required for access in this design).

(g) Operable without time-dependent controls.


Time-outs can be modified via preferences menu

- Menu option. (easily implemented in software)

(h) Operable without speech.


Speech input of commands not required; Text communication modes available.

- Ability to control phone without requiring speech is standard on most all phones.
- Text communication is common on digital phones and will be standard soon.

(i) Operable with limited cognitive skills.


EZ Access - all functions accessible via speech output; Also one-button / single number dialing with optional cover plate; Infrared port - allows user programming via simplified step-by-step computer interface

- Speech output of all printed text is already covered above (first item).
- One button dialing and single number dialing is software only.
- Optional cover plate would cost a bit but is not needed for access.
- IR port is standard on many cell phones

Sec. 1193.43 Output, display, and control functions.

FCC Guideline Guidelines Met? How the requirements are met. Cost & Ease of Implementation (If a company had been doing this as a matter of course. e.g. does not include cost of acquainting engineers with access.)

(a) Availability of visual information.


EZ Access - all functions and displayed text available via speech

- Cost covered above.

(b) Availability of visual information for low vision users.


Matrix Display - all functions and messages shown in large print on display

- A small addition to software to have the phone display the words when it speaks them as discussed above.

(c) Access to moving text.


Arrow buttons - text can be paused or stepped through using arrow buttons - configurable via preferences menu

- Preferences menu option (easily implemented in software)

(d) Availability of auditory information.


Ringing tones, beeps shown on display (and vibrating ringer). TTY messages shown on display. Speech to Text available via relay services. VCO supported.

- Using the Lucent solution strategy (or final standard), TTY codes can be decoded in digital phones using software. A little additional software would allow TTY text to be displayed.
- All other sounds made by the phone can be visually displayed as well using existing displays.

(e) Availability of auditory information for people who are hard of hearing.


Full FCC volume range.

- Cell phones already exist that meet the FCC specified levels

(f) Prevention of visually-induced seizures.


Flashing lights all within acceptable flash frequencies.

- No cost. Not a problem on most phones today.

(g) Availability of audio cutoff.


Headset being placed in jack cuts off the speaker

- Standard industry practice.

(h) Non-interference with hearing technologies.


Per Standards group ANSI C63

- Already being addressed by industry.

(i) Hearing aid coupling.


Hearing aid t-coil compatibility

- Already common in many phones including world's smallest mass market cell phone.

Subpart D - Compatibility

Sec. 1193.51 Compatibility

FCC Guideline Guidelines Met? How the requirements are met. Cost & Ease of Implementation (If a company had been doing this as a matter of course. e.g. does not include cost of acquainting engineers with access.)

(a) External electronic access to all information and control mechanisms.


Infrared port allows activation of all features remotely.

- Already common in many cell phones (including Nokia's most popular model). Only software protocol needs to be added.

(b) Connection point for external audio processing devices.


Standard subminiature headset jack connects to external auditory processing devices

- Hardware for this is already used by most cell phone companies for connection of headsets (including world's smallest mass market cell phon).
- No cost to use standard signal levels.

(c) Compatibility of controls with prosthetics.


Keys do not require contact with human body to work. Dished keys make it easier to press keys for people with limited manipulation.

- Not aware of any phones that fail this guideline today (though there probably is one).
- Most (non-cell) phones also have dished keys like the old touchtone phones.

(d) TTY connectability.


Headset jack is a TTY connector

- Headset jack already used as TTY connector today for some TTYs. (see also next item)

(e) TTY signal compatibility.


Phone can send and receive TTY signals.

- One of 3 industry proposed all software solutions is used. (which work with today's phones.)

* Note: The access package above can be implemented with or without a separate green diamond "EZ" button. Implementation with the button is preferable. The cost for the extra button is in the cents range if done as part of the overall original keyboard design.

This reference design is a project of the Trace Research and Development Center and was funded in part by the National Institute on Disability and Rehabilitation Research of the Department of Education under grant numbers H133E50002, H133A60030, and H133E980008. The opinions contained in this course are those of the grantee and do not necessarily reflect those of the Department of Education.


Image of the Trace Center logo.
Trace Research & Development Center
College of Information Studies, University of Maryland
Room 2117 Hornbake Bldg, South Wing
4130 Campus Drive
College Park, MD 20742
Copyright 2016, University of Maryland
Tel: (301) 405.2043
Fax: (301) 314.9145
Trace Center