ADA FAQ

ADA FAQ Kiosks – Common Questions

We get questions on ADA for Kiosks and our ADA FAQ is intended to provide those questions and answers. If you have any further questions you can contact KMA at [email protected]

As a reminder, strictly speaking, 508 only applies to kiosks in the federal space.  Of course, it is a good set of ICT accessibility requirements.

The ADA Accessibility Guidelines (ADAAG) covers ATMs and Fare vending machines, but not kiosks more generally.

The Air Carrier Access Act (ACAA) covers kiosks at airports.

For more information we recommend the U.S. Access Board which will answer questions and conducts regular webinars on accessibility.

Common ADA Kiosk Questions

ADA Compliance

Does WCAG apply to or specified for kiosks?

Short Answer – No, it is not applied to kiosks.

Long answer – WCAG applicability to hardware is problematic. It may be that EN 301 549 has WCAG applicability for kiosks. The U.S. Access Board apply WCAG to non-web documents and non-web software, but only when the software is running on platforms that are not “closed”.  Kiosks, of course, typically are closed, and so (from a 508 perspective), the WCAG 2.0 SC are never applied.  The reach range stuff and the section 402 Closed Functionality are the bulk of the requirements.  Many of the areas that WCAG 2.1 addresses are also addressed in ADA and Section 508 so in a virtual sense there is some applicability.

Doesn’t accessibility under Section 508 only apply to federal agencies? As a corporation I am not bound by those regs right?

Short Answer – Correct.

Long answer – ADA does not have requirements for web content or other IT, except for ATMs and fare vending machines.  That said, the courts have pretty consistently ruled that web sites are covered under ADA as part of the general requirements for non-discrimination and “effective communication”.  Since ADA does not have specific metrics for web content, the courts have used WCAG or 508 as the measure for accessibility.

Attended Assistance

If I provide assistance via a person in my store should eliminate the need for accessibility. Isn’t that good enough?

A: Short answer is Generally Not.

Longer answer – Having the kiosks staffed is taking the “self” out of “self-service”.  But if the kiosk are staffed, or at least sufficiently staffed so that everyone has good opportunity to get help, a business is probably at low risk with such an approach.  Assuming that only people with disabilities need the option of having a person assist them is a high risk approach (in our opinion), and (to the best of our knowledge) not at all well supported by case law.

Where the regulations do have clear requirements for self-service kiosks (i.e.:  kiosks under 508, ATMs and fare vending machines under ADA, and airline ticketing kiosks under ACAA), personal assistance is not permitted as a substitute for conformance with the accessibility requirements.

Audio

Are kiosks required to provide permanently plugged-in headphones, not just the earbud jack?

No. No accessibility standards require attached headphones.  Attached headphones sound likes a very bad idea for unattended equipment, as they would be a risk for vandalism and hard to keep sanitary.  Headphones are sometimes used in museum style environments.

Ref:

402 Closed Functionality

402.1 General. ICT with closed functionality shall be operable without requiring the user to attach or install assistive technology other than personal headsets or other audio couplers, and shall conform to 402.

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.

Keyboard

Is a Keyboard Required for ADA compliance

The short answer is No.

The longer answer is:  “most probably not, but it depends on the content being interacted with”.

The requirement is that operable parts be discernable by touch without activation.  That requirement is problematic for touch screens, so kiosks typically need to provide alternative controls for users that are blind.

Those alternative controls might be a keypad (as is the case with ATMs and fare vending machines).

With kiosks (like the new airport ticketing machines) the most popular approach is to add the Trace EZ Access keypad.

However, there is a difficulty if the interaction with the kiosk ever requires the user to enter alphabetic characters, since an on-screen keyboard is useless for someone who is blind.

If the alphabetic key entry is not very many characters, then the Trace EZ Access keypad is just barely sufficient.  The user has to scroll through 26 letters (or more, if a field is alphanumeric).

On the other hand, the kiosk might be more general purpose, and interaction with an on-screen keyboard is a core feature of using the kiosk.  An example is a kiosk at Motor Vehicles where the user has to enter name, address, and other demographics.  Another example is a kiosk that provides for web browsing.

To be ADA compliant, those sort of kiosks require a physical keyboard, with the keys arranged qwerty style, and with tactile indicators for finding the F and J keys on the home row.

To be sure, given your particular situation, it is recommended you have someone like TFA conduct a Gap Analysis. Also, ADA and accessibility isn’t just the kiosk, it can be the facilities and where the kiosk is situated.  Architectural ADA has a higher incidence of liability overall.

Is a Keyboard Required for ADA Compliance – Part 2

The following may be enough information to support the requirement for tactile controls:

  • Most technical standards for accessible design such as Section 508, D.O.T. and ADA include a requirement for tactilely discernible input controls.

Examples:

Section 508:

“Tactilely Discernible. Input controls shall be operable by touch and tactilely discernible without activation.”

DOT: 

“Input controls. At least one input control that is tactilely discernible without activation must be provided for each function.”

ADA:

“Input Controls.  At least one tactilely discernible input control shall be provided for each function. ”

  • Tactile input controls benefit users who are unable to use a touch screen.
    • One approach to designing an accessible kiosk interface for blind users is to provide tactile input controls with speech output.
  • While it is possible to create an accessible touch screen interface for blind users (the technology is built into iOS and Android devices) kiosks must also provide tactile controls.
  • The Section 508 standards include an exception to the tactile controls requirement but this only applies to devices for personal use.
  • People who have difficulty activating touch screen controls because of hand tremors, limited dexterity or other reasons may be better able to interact with the kiosk using tactile controls.

In related legal matter, in 2 recent cases that legal actions brought up against kiosk manufacturers, the advocacy group & regulatory agency explicitly asked the manufacturer to include hardware solution which requires tactile control (such as Storm device), in one case the kiosk manufacturer suggested to introduce software solution but it was rejected by the advocacy group.

Reach

Do operable parts like a credit card reader need to be detachable to improve accessibility?

No. As long the operable parts (touchscreen, card reader, etc) are within reach requirements then you are fine. Reference 407.8 of Final Rule  January 2017