Accessibility – A Look At WCAG and Overall Self Service

essential guide to EAA

Accessibility Update April 2025 – Web and WCAG

Accessibility Update 2025 — We encourage accessibility.  Accessible self service is the ideal for us. If we had one wish, it would be that self-service accessibility for all be treated much like safety. Seat belts and airbags benefit everyone. They are not optional for auto manufacturers. Emissions control is another. I drive a 2006 Acura TL and it would not be allowed on the road in China. From kioskindustry.org

The value of a single aspect detail checklist like below is that we need 20 or 30 other ones like this, covering the different aspects of self-service, and not just a web interface on a desktop computer screen.  Most of us use mobiles anyway.

We have our basic checklist, but we would like to expand those items into actions. In the kiosk and digital signage world we have to think about multiple factors

    • hardware  (includes Mobiles)
    • software
    • Pre-deployment usability using personas.
    • installation
    • site surveys
    • Connectivity (good luck getting decent internet in rural?)
    • Ongoing service
    • Post deployment surveys of customers for what we got right and what we got wrong
    • Application flow  (much like proper syntax in sentence structure.  e.g. — Accessibility self-service for important is people use can everyone when easy not if.) All the checkboxes checked but good luck making sense.
    • When clients do their own software kiosk manufacturers are at their mercy and never see the code fyi*

Insight — with the onset of “AI Fever” there are already examples of transactional processes being needlessly confused and diverted due to AI.

Note: current website project if interested — The City of Dallas (“the City”) invites information from established vendors or providers specializing in State and Local government technology services, specifically digital agencies/companies experienced with redesign, redevelopment, maintenance and management of external / public facing websites. The project scope includes user research to review the effectiveness of current websites (both the homepage and department specific pages), development of revised architecture, design and templates; content migration; and recommendations for new service-based functionality. The City is interested in responses from those with proven experience in the website design, redesign, migration, upgrade and ongoing maintenance sector.  01- Specifications- Website Redesign and Maintenance RFI Specs Final (002)

Examples of Good WCAG Testing

Features used to enhance accessibility:

  • Focus on using semantic HTML for better page performance, more enhanced SEO rankings, better mobile optimizations, built-in functionality, and screen reader compatibility.
  • Information, structure, and relationships are conveyed programmatically in the product.
  • Using ARIA where HTML elements do not provide enough detail or information.
  • Textual equivalents are provided for all non-textual elements.
  • Using a mechanism to bypass blocks of content that are repeated on multiple web pages.
  • All forms and form elements are designed for accessibility.
  • Labels or instructions are provided in the product when content requires user input.
  • Color recognition is not required to convey information.
  • The visual presentation of all text and images of text in the product have a contrast ratio that meets the minimum requirements.
  • Focusable components in the product receive focus in an order that preserves meaning and operability.
  • Data tables are clearly identified for logical use.
  • Style sheets are not required to view content.
  • No multimedia elements are used.
  • Animation is not utilized in applications.

Ongoing accessibility initiatives include:

  • Review and application of updated guidelines as they are released.
  • Continuing assessment of application software and development processes as they relate to future guidelines.
  • Ongoing review, documentation and remediation of all end user applications using internal audits, development and testing processes.
  • Evaluate the applications with NVDA, Deque Axe Accessibility Chrome extension, WebAIM WAVE Tool, WebAIM Color Contrast Checker, Windows accessibility settings, manual keyboard checks, third party (Deque, Level Access) automated and end user testing.
  • Engage clients, students and users if issues are reported. We ask them to describe and or document the issue(s) found, demonstrate with assistive technology and test the results of our remediation.
  • Work with third party providers to review, document, remediate issues and provide detailed VPAT documentation based on WCAG 2.1 AA (and continuing to evolve based on newer versions of WCAG).

About WCAG

The most recently released version of the Web Content Accessibility Guidelines (WCAG) is WCAG 2.2. It was officially published as a W3C Recommendation on October 5, 2023, with an update released on December 12, 2024267. WCAG 2.2 adds nine new success criteria to those in WCAG 2.1 and removes one obsolete criterion (4.1.1 Parsing), aiming to improve accessibility for users with cognitive disabilities, low vision, and limited fine motor skills678.

WCAG 2.2 is now the recommended standard for web accessibility, but it does not deprecate or supersede WCAG 2.1 or 2.0. All three versions remain valid, though the W3C encourages organizations to use the most recent version—WCAG 2.2—for the greatest future applicability127.

A future major version, WCAG 3.0, is still under development and has not been released. It is expected to become a W3C standard in several years458.

Breakdown of Age Generations in the U.S. (2023-2025)

Note: that we have excluded the Jones Generation (I am in that one).

Here is a summary of the primary generational cohorts in the United States, their typical birth years, current age ranges, and their estimated share of the U.S. population:

Generation Birth Years Age in 2025 % of U.S. Population (2023)
Silent Generation 1928–1945 80–97 Not specified
Baby Boomers 1946–1964 61–79 73 million
Generation X 1965–1980 45–60 65 million
Millennials 1981–1996 29–44 73 million
Generation Z 1997–2012 13–28 69 million
Generation Alpha ~2013–2024 1–12 38 million

What about Disability Ratios?

  • Baby Boomers — 24% (65–74), 46% (75+)
  • Gen X — 12% (35–64); up to 36% self-report
  • Millenials — 8% (<35); up to 33% self-report
  • Gen Z — 8% (<35); 42% mental health dx
  • 37 Million disabled or impaired total?
  • 340 Million total population in US
  • Retail shoppers =  135 million
  • Online = 274 million
  • How many consumers prefer using self-service? —  77% — 80% express interest.
  • Total self-service user base? 110 Million
  • percentage of those with some form of disability?  33%

Key Details:

  • Millennials (born 1981–1996, ages 29–44 in 2025) are the largest generation group, making up about 21.71% of the U.S. population in 202342.

  • Generation Z (born 1997–2012, ages 13–28 in 2025) accounts for around 20.69% of the population47.

  • Baby Boomers (born 1946–1964, ages 61–79 in 2025) are the second-largest group, though their numbers are shrinking as the population ages257.

  • Generation Alpha (born early 2010s–2024, ages 1–12 in 2025) is the newest named generation and is said to make up a significant share of the population, with some estimates suggesting around 42.75%, though this figure may include overlap with younger Gen Z27.

  • Generation X (born 1965–1980, ages 45–60 in 2025) is smaller than Boomers and Millennials but will surpass Boomers in population by 2028 as the latter cohort ages57.

Note: The exact percentage for some generations (Silent, Gen X) is not specified in the latest available data, but Millennials and Gen Z together make up over 42% of the population as of 20234.

Major Disabilities and Impairments in the U.S. Population

More than 1 in 4 adults in the United States—over 70 million people—report having some type of disability, according to the latest CDC data from 2022214. The most common types of disabilities and their prevalence among U.S. adults are as follows:

Disability Type % of U.S. Adults Estimated Number of Adults (2022)
Any disability 28.7% 70+ million214
Cognitive disability 13.9% ~34 million145
Mobility disability 12.2% ~30 million145
Independent living 7.7% ~19 million15
Hearing disability 6.2% ~15 million135
Vision disability 5.5% ~13 million135
Self-care disability 3.6% ~9 million1

Definitions and Examples

  • Cognitive disability: Serious difficulty concentrating, remembering, or making decisions. Includes learning disabilities, intellectual disabilities, autism, ADHD, and memory loss145.

  • Mobility disability: Serious difficulty walking or climbing stairs. Includes conditions like arthritis, muscular dystrophy, multiple sclerosis, and spinal injuries15.

  • Independent living disability: Difficulty doing errands alone, such as visiting a doctor or shopping15.

  • Hearing disability: Deafness or serious difficulty hearing135.

  • Vision disability: Blindness or serious difficulty seeing even when wearing glasses135.

  • Self-care disability: Difficulty dressing or bathing independently1.

Additional Insights

  • Disability prevalence increases with age, affecting 16% of adults aged 18–44, 29% of those aged 45–64, and about 50% of individuals over 654.

  • Rates are higher among Black (31%) and Hispanic (30%) adults compared to white adults (24%)4.

  • Many adults experience more than one type of disability3.

These figures underscore the significant impact of disability across U.S. society and highlight the importance of accessibility and support for individuals with a wide range of impairments.

How many buying cycles for a Baby Boomer compared to Millenial?

Yes, Baby Boomers have fewer years left to buy cars compared to Millennials.

  • Life Expectancy: Most Baby Boomers (born 1946–1964) are currently between 61 and 79 years old. The average life expectancy for Boomers is around 79–88 years, depending on gender and health1356. This means the oldest Boomers may have less than a decade, and the youngest up to 20–25 years, of car-buying years left.

  • Current Car-Buying Patterns: Despite their age, Boomers are still very active car buyers. In fact, the 55-to-64 age group (older Boomers) is currently the most likely to buy a new car, and even those over 75 buy cars at higher rates than some younger groups24.

  • Generational Shift: As Boomers age into their 80s, car buying will naturally decline due to reduced mobility, health issues, and eventually, the cessation of driving1356. Millennials, being younger, have many more years ahead for car purchases.

In summary: Boomers are still strong contributors to car sales, but their remaining years for buying cars are limited compared to Millennials, who have several decades of car-buying ahead of them1256.

In Practice:

  • Over a typical adult lifespan, both Baby Boomers and Millennials are likely to purchase between 6 and 8 vehicles (new and used), assuming average car replacement every 7–10 years over a 50–60 year driving lifetime (from age 18 to 75+).

  • Millennials may buy cars at a slightly slower rate early in adulthood, but this gap closes as they age and their life circumstances converge with those of Boomers38

 

PIN On Glass” POG — Is it OK?

PIN on Glass

Touch Screens and “PIN On Glass” POG — Is it OK?

Touchscreen Payment Via Pin On Glass (POG) via Android

We were asked about using Pin on Glass.  Would be nice to get rid of numeric keypad.

Comment from Datacap: Yes, PIN on Glass is supported in the US. It’s generally supported via purpose-built PCI PTS devices that have certified PoG with EMVCo and/or on COTS (consumer off-the-shelf) devices via a SoftPOS (contactless payments only) implementation. That being said, PIN on SoftPOS is still pretty rare in the US. Expect to see it more over the next year or two as SoftPOS adoption gains momentum.

For a payment kiosk in the U.S., PIN-on-Glass (PoG) technology is generally acceptable, provided it meets specific security standards and certifications. Here’s what you need to know:

Overview

Acceptability and Standards

PIN-on-Glass is an evolving technology in the payment industry that allows customers to enter their PIN on a touchscreen device rather than a physical keypad

. For a payment kiosk to use PoG in the U.S., it must adhere to strict security requirements:

  1. PCI Certification: The device must be certified by the Payment Card Industry Security Standards Council (PCI SSC)
  2. Hardware Requirements: The kiosk should use PCI PTS (PIN Transaction Security) approved hardware-based point of interaction (POI) devices built on a mobile device platform
  3. Software Requirements: If using a software-based solution, it must comply with the PCI Software-based PIN Entry on Commercial Off-The-Shelf (SPoC) standard

Security Measures

PoG solutions incorporate multiple layers of security to protect sensitive data:

  • Encryption of PIN and payment information
  • Tamper detection mechanisms
  • Secure boot processes
  • Isolation of PIN from other cardholder data

Considerations for Implementation

When implementing PoG for a payment kiosk in the U.S., consider the following:

  1. Compliance Deadlines: Be aware of any mandates from card brands. For example, Visa announced a sunset date for non-approved SPoC solutions
  2. Accessibility: Ensure the kiosk can accommodate customers with disabilities to avoid potential legal issues
  3. Consumer Trust: Some customers may be hesitant to use PoG technology, particularly in areas with strong “Protect your PIN” awareness programs
  4. EMV Transactions: PoG solutions often focus on EMV (chip) transactions rather than magnetic stripe, which enhances security

In conclusion, PIN-on-Glass is acceptable for payment kiosks in the U.S., provided the solution meets PCI standards and incorporates robust security measures. As the technology continues to evolve, it’s crucial to stay updated on the latest requirements and consumer preferences to ensure successful implementation.

Legal Considerations

Accessibility Issues

Merchants using PIN-on-Glass solutions need to be aware of potential legal risks related to accessibility:

  • Many jurisdictions, including the US, Canada, and the EU, have laws aimed at providing accessibility for disabled individuals
  • A merchant offering payment only via PIN-on-Glass could be at risk under these laws, as there have been lawsuits filed in the US over the use of touch screens and apps
  • Merchants need to do their due diligence to ensure they can accommodate customers with disabilities, or they may find themselves facing legal action

Security and Compliance Requirements

There are also legal implications related to security standards and compliance:

  • Merchants must use PCI-approved Secure Card Reader for PIN (SCRP) devices
  • PIN-on-Glass solutions must comply with the PCI Software-based PIN Entry on COTS (SPoC) standard
  • Visa has mandated that merchants accepting PIN-based transactions via COTS devices must use or transition to a PCI-validated software-based PIN entry on COTS solution
  • Failure to comply with these standards could result in legal liability in case of data breaches or fraud.

Consumer Protection Laws

Merchants may face legal risks related to consumer protection:

  • If proper security measures are not in place, merchants could be held liable for fraudulent transactions or data breaches.
  • Consumers may have legal recourse if their PIN data is compromised due to inadequate security measures.

Contractual Obligations

Merchants should be aware of potential contractual implications:

  • Agreements with payment processors or acquiring banks may require compliance with specific security standards for PIN entry.
  • Failure to meet these contractual obligations could result in legal disputes or termination of services.

To mitigate these legal risks, merchants should ensure they are using PCI-compliant PIN-on-Glass solutions, provide accessible alternatives for customers with disabilities, and stay informed about relevant laws and regulations in their jurisdictions

Where is Pin Use Relevant

Debit Card Transactions

PIN is most commonly used with debit cards in the following scenarios:

  • ATM Withdrawals: When withdrawing cash from an ATM, entering a PIN is typically required
  • Point-of-Sale (POS) Purchases: Many merchants offer the option to use PIN for debit card purchases. When using a debit card at a store, customers can often choose between “debit” (which requires PIN entry) or “credit” (which may require a signature)
  • Cash Back at Retailers: When getting cash back during a purchase at a store, PIN entry is usually required

Credit Card Transactions

While less common, PINs can sometimes be used with credit cards:

  • Cash Advances: When using a credit card to withdraw cash from an ATM, a PIN is typically required
  • Chip and PIN Cards: Some credit cards, particularly those designed for international use, may use chip and PIN technology. However, this is less common in the U.S. compared to other countries

Online and Mobile Transactions

  • Two-Factor Authentication: Some banks use PINs as part of their two-factor authentication process for online or mobile banking transactions

Additional Considerations

  • Signature vs. PIN: In the U.S., signature-based transactions are still common, especially for credit cards. However, PIN-based
  • Merchant Discretion: Some merchants may prefer PIN transactions due to potentially lower processing fees, while others may opt for signature-based transactions
  • Contactless Payments: With the rise of contactless payments, some transactions may not require PIN entry for small amounts

It’s worth noting that the use of PINs in the U.S. is less prevalent compared to some other countries, particularly for credit card transactions. However, for debit card usage, especially at ATMs and for cash back at retailers, PINs remain a standard security measure.

EUROPE

Contactless Payments

Contactless payment has become increasingly prevalent across Europe, reducing the need for PIN entry for many transactions:

  • Most purchases under €50 (or the local equivalent) can be made without entering a PIN
  • Using mobile payment methods like Apple Pay or Google Pay often eliminates the need for PIN entry, even for larger purchases

Chip and PIN

Despite the rise of contactless payments, chip and PIN technology remains standard in many European countries:

  • For transactions exceeding the contactless limit, a PIN is typically required
  • Some countries, like France, have implemented “PIN Online” verification, where the PIN is verified directly with the bank’s server rather than the card chip

Variations by Country and Merchant

The use of PINs can vary depending on the specific country and merchant:

  • In Germany, some establishments may only accept cash or specific cards like Eurocard
  • Unattended payment points (e.g., ticket machines, parking garages, self-service gas pumps) often require chip and PIN cards

American Cards in Europe

For American travelers using US-issued cards:

  • Many US cards now work with contactless payments in Europe
  • Some US cards may still default to chip and signature rather than chip and PIN
  • At manned terminals, signature-based transactions are usually accepted, but automated kiosks may require a PIN

More PIN on Glass and PIN on Mobile Background

  • 2022 Ingenico — What’s the Difference Between PIN on Glass and PIN on Mobile?  With Apple’s recent announcement of Tap to Pay on iPhone, use of mobile devices to accept payment at the point of sale continues to gain traction. With that in mind, I thought it was important to discuss the differences between PIN on terminal, PIN on glass and PIN on mobile, as card authentication will continue to play a big role in how tap to pay on mobile devices will ultimately work.
  • 2020 — What is PIN on Glass – Trustonic

More Links

Author: Staff Writer   Craig Keefner — With over 40 years in the industry and technology, Craig is widely considered to be an expert in the field. Major early career kiosk projects include Verizon Bill Pay kiosk and hundreds of others. Craig helped start kioskmarketplace and formed the KMA. Note the point of view here is not necessarily the stance of the Kiosk Association or kma.global

IAAPA Kiosks and More

Visit us at IAAPA

IAAPA Kiosk Update – 2024 – Pyramid, TPGi, RedyRef & AcquireDigital

iaapa kiosk

IAAPA Ticketing Kiosks

Booth 5727 — Show floor is Nov 19-22 — Orlando Florida. Here is main IAAPA website.  In 2024 for our IAAPA kiosk show we will have four member companies featured.  Here is registration link and highly recommended to download the app for your phone. This year, the show information will be more robust on the phones in the app than on the usual exhibitor portal desktop page.

Free invites. We can give you free invite code. Email [email protected] — you can also visit kioskindustry.org where we have the code listed.

For more info, free pass or to set up a meeting:

  • send email to craig at [email protected] or you can text me at 720-324-1837
  • More member emails below

Pyramid Show Panel – [email protected]



TPGi Show Panel – [email protected]


RedyRef Show Panel  — [email protected]

 


AcquireDigital Show Panel — [email protected]


 

iaapa floor

 

U.S. Access Board Meeting and Webcast (October 30)

U.S. Access Board October

Update 11/8/2024: Here is excerpt from meeting with comments by Sachin.  Led with SSTM status which is undergoing review by OMB. Once completed will be issued for comments. Possible date Feb 1st, 2025.

All are welcome to attend the next meeting of the U.S. Access Board, which will be open to the public and take place virtually on October 30 from 1:30 – 3:00 p.m. (ET). The agenda for the meeting includes brief reports from standing and ad hoc Board committees, federal agency updates, and a report by Executive Director Sachin Pavithran.

US Access Board News

US Access Board News

Members of the public may attend the meeting through the Zoom.gov platform or by phone (listen-only mode). Please note that participation over Zoom will require the use of the passcode provided below. For further information, contact Rose Marie Bunales at [email protected].

Meeting of the U.S. Access Board
October 30, 2024, 1:30 PM – 3:00 PM (E.T.) Zoom: https://www.zoomgov.com/j/1616536186
Meeting ID: 161 653 6186
Passcode: 128200
Dial in: (646) 828-7666
Contact: [email protected]


Related Access Board Articles


From MS Pilot

The U.S. Access Board is an independent federal agency that promotes equality for people with disabilities. It achieves this through leadership in accessible design and the development of accessibility guidelines and standards for various environments and technologies.

Key Functions:

  • Developing Accessibility Standards: The Board creates and maintains design criteria for the built environment, transportation, communication, medical diagnostic equipment, and information technology.
  • Providing Technical Assistance: It offers guidance and training on accessibility standards to help ensure compliance and promote best practices.
  • Advancing Inclusive Design: The Board works to ensure that public spaces and services are accessible to all, including sidewalks, crosswalks, and public transportation.

Recent Initiatives:

  • Electric Vehicle Charging Stations: Seeking public comment on proposed rules to make EV charging stations accessible.
  • AI and Disability: Hosting hearings on the impact of artificial intelligence on the disability community.
  • COVID-19 Home Tests: Publishing best practices for designing accessible COVID-19 home tests.

For more detailed information, you can visit their official website1.

Guidance on WCAG 2 for Non-Web Information 2024

W3C

WCAG2ICT Published as W3C Group Note

US Access Board News

US Access Board News

On October 8th, 2024, the W3C Accessibility Guidelines Working Group (AGWG) published Guidance on Applying WCAG 2 to Non-Web Information and Communications Technologies (WCAG2ICT) as a completed W3C Group Note. WCAG2ICT describes how Web Content Accessibility Guidelines (WCAG) principles, guidelines, and success criteria can be applied to non-web information and communications technologies (ICT), specifically to non-web documents and software. The Note includes guidance for WCAG 2.0, 2.1, and 2.2 success criteria and glossary terms. For an introduction, see: WCAG2ICT Overview.


On October 8th, 2024, the W3C Accessibility Guidelines Working Group (AGWG) published Guidance on Applying WCAG 2 to Non-Web Information and Communications Technologies (WCAG2ICT) as a completed W3C Group Note. WCAG2ICT describes how Web Content Accessibility Guidelines (WCAG) principles, guidelines, and success criteria can be applied to non-web information and communications technologies (ICT), specifically to non-web documents and software. The Note includes guidance for WCAG 2.0, 2.1, and 2.2 success criteria and glossary terms. For an introduction, see: WCAG2ICT Overview.

The WCAG2ICT Group Note has been a key resource for including WCAG in ICT accessibility regulation, legislation, and other standards around the world. The updated WCAG2ICT now facilitates further adoption of WCAG 2.1 and WCAG 2.2 in non-web contexts.

Example: Examples of technology that may have closed functionality include but are not limited to:

  • self-service transaction machines or kiosks — examples include machines used for retail self-checkout, point of sales (POS) terminals, ticketing and self-check-in, and Automated Teller Machines (ATMs).
  • telephony devices such as internet phones, feature phones, smartphones, and phone-enabled tablets
  • educational devices such as interactive whiteboards and smart boards
  • entertainment technologies including gaming platforms or consoles, smart TVs, set-top boxes, smart displays, smart speakers, smart watches, and tablets
  • an ebook reader or standalone ebook software that allows assistive technologies to access all of the user interface controls of the ebook program (open functionality) but does not allow the assistive technologies to access the actual content of book (closed functionality).
  • medical devices such as digital blood pressure monitors, glucose meters, or other wearable devices
  • an operating system that makes the user provide login credentials before it allows any assistive technologies to be loaded. The login portion would be closed functionality.
  • other technology devices, such as printers, displays, and Internet of Things (IoT) devices

More WCAG Non-Web

Check In Kiosks — SSA Kiosks Test Tool Included Section 508 ICT

ssa kiosk ada

New SSA Kiosks

From kioskindustry.

New SSA Check-In Kiosks Deployed

SSA check-in kiosks being deployed and they are brand new — From Montgomery Advertiser — down below we include actual tested parameters and the tool SSA uses along with spreadsheet with results.

Here are the key points:

  • New Kiosks: Social Security offices have installed new kiosks to improve accessibility and privacy. These kiosks are ADA-compliant and easy to use.
  • Enhanced Check-In: Modifications have been made to assist customers who are blind or have low vision.
  • Mobile Check-In Express: Customers can now use their mobile devices to check in by scanning a QR code, making the process faster and more convenient.
  • Commitment to Accessibility: Social Security is dedicated to enhancing customer service and accessibility through these new technologies.

Excerpt:”Exciting News: Introducing New SSA Kiosks

At Social Security we strive to make our services more accessible while maintaining your privacy. We installed new kiosks in most of our local offices to make it easier for you to check in and conduct business with us. The kiosks are private, easy to use without assistance, and provide consistent service to our customers.

Modifications to earlier screens have improved the check-in process, especially for our customers who are blind or have low vision. Each kiosk is compliant with the Americans with Disabilities Act (ADA) and includes the following features:

  • Accessible keypads.
  • Audio headphone jacks (complimentary headphones are available upon request).
  • Braille instructions for how to use the kiosk and report any accessibility issues.
  • Built-in thermal printers and ticket dispensers.
  • Enhanced 508-compatible check-in software.
  • Touchscreen monitors with privacy filters.

Here is a look at some of the parameters tested for.

ssa kiosks ada

ssa kiosks ada – click for full size

Actual worksheet used

SSA-508-Test-Method–Kiosk

SSA 508 Test Method

The Social Security Administration uses an Accessibility Test Method based on the Section 508 ICT Testing Baseline. Our Test Method is a process to determine conformance of with the Revised Section 508 of the Rehabilitation Act (29 U.S.C. 794d).

The Social Security Administration uses ANDI as its primary, manual accessibility testing tool for web content.

https://www.ssa.gov/accessibility/testmethod.html?tab=1


Thanks to

William D. Goren, Esq., J.D., LL.M.

EV Charging Station Regulations

EV Charging ADA

U.S. Access Board Seeks Public Comment on Proposed Rule for Electric Vehicle (EV) Charging Stations

On September 3, the U.S. Access Board published a notice of proposed rulemaking (NPRM) to amend the EV charging regulations and accessibility guidelines for buildings and facilities covered by the Americans with Disabilities Act of 1990 (ADA) and the Architectural Barriers Act of 1968 (ABA) to specifically address the accessibility of electric vehicle (EV) charging stations. This proposed rule provides specifications for the accessibility of EV charging stations, to include the EV charger (including physical and communication access), EV charging space, access aisles, and accessible routes. The public can review the docket and read background documents or comments received on the docket webpage.

“The Access Board seeks the public’s feedback and comments on our proposed rulemaking on EV charging stations. As technology advances, so must our accessibility standards to ensure that Americans with disabilities have equal access to advancements in technology, such as electric vehicles,” remarked Executive Director Sachin Pavithran. “This is an opportunity for the public to engage with the Access Board’s rulemaking, and we look forward to reviewing your public comments as we move our rulemaking efforts forward.”

More Posts on EV Charging Regulations

Background

There are several key regulations in place for EV charging stations in the United States:

  1. Installation, Operation, and Maintenance: Charging stations must meet specific standards for installation, operation, and maintenance. This includes having a minimum number of ports, types of connectors, and payment methods1.
  2. Interoperability: The infrastructure must be interoperable, meaning it should work seamlessly with different types of EVs and charging networks1.
  3. Accessibility: There are requirements to ensure that EV charging stations are accessible to all users, including those with disabilities. This includes provisions for accessible routes and operable parts2.
  4. Data and Connectivity: Charging stations must provide data on their locations, pricing, real-time availability, and accessibility. This information should be accessible through mapping applications1.
  5. Signage: Proper traffic control devices or on-premises signage must be installed in concert with the EV charging infrastructure

Mobile Apps and Accessibility

smart city

Accessible Mobile Apps

Generally we stay focused on kiosks here at the KMA.  Having said that, oftentimes in-house development projects for “unattended customers” which involve kiosks, often involve mobile apps and even websites for that matter. Here is a look from kioskindustry on mobile accessibility

Excerpt:

Accesssible Apps From LinkedIn Collaboration

Your team values speed over accessibility. How can you ensure inclusivity while meeting tight deadlines?

Accessible apps – When time is of the essence, it’s essential to identify the accessibility tasks that will have the most significant impact. Start by implementing keyboard navigation and ensuring that all content is accessible through assistive technologies. This doesn’t have to be time-consuming; simple adjustments to HTML can make a big difference, such as using &lt;header&gt; , &lt;nav&gt; , and &lt;footer&gt;elements for better document structure.

Our perspective on accessible apps  (747 words)
Start with identifying main channels and percentages. How much desktop versus mobile? Probably more mobile (60%?) and accessibility considerations are different for both. Is it Europe or US? They are different. https://kioskindustry.org/standards/ is good start point to learn how we think about kiosk accessibility and standards. Most of them apply in part to mobile.

For testing mobile I suggest the Section 508 Mobile Standards Testing summary by VA. Checking mainstream web accessibility use google pagespeed and MS edge. Generally just tune your stylesheet. Simple and easy. Takes 20 minutes. Arias and menu picklists are the real pains and they are easy too.

A slow site is less accessible as well.

New standards from US Access Board come out in next 60 days. New legal liabilities. Large companies are often held for ransom by lawyers.

Reply

Don’t forget iOS versus Android either. Great thing about pagespeed is it looks at it from Mobile perspective, then Desktop. Plus it tells you how fast or slow. Lighthouse in developer tools is another option and so is ARC from Vispero. All free.
Editors Note:  We do recommend experienced consultants in unattended customer input space and those would be TPGiTech For All and Dolphin. Very useful and in particular for kiosk applications. Often – the overall project codebase will include not only mobile but POS, kiosks and web. It is also worth noting that while no definitive stats the general consensus is that the disabled community grew up on iOS and uses it more than Android.

More Posts on Accessible Mobile

Airport Kiosks – Does ADA Discriminate against Tall People?

Standing Tall – Does ADA Discriminate?

Editors Note: Being able to think critically about ADA is good practice.  There are many forms of accessibility and many of those are ignored in favor of the more popular. The writer is expressing their own opinion and not Kiosk Industry Group/Self Service Kiosk Machine.  Discussion was stimulated (see comments below) and that was outcome we sought.

Christoph Nussbaumer CEO of Alpine Kiosk

Christoph Nussbaumer CEO of Alpine Kiosk

About the WriterChristoph Nussbaumer is the CEO of REINGroup based in Austria. Alpine Kiosk boasts a diverse array of designs, each is highly adaptive and radiating elegance and sophistication.  Alpine Kiosk – Where each design is a testament to premium craftsmanship.  Alpine Kiosk is Gold Supporter of Kiosk Industry Group and member of the KMA Kiosk Association. His viewpoint from Europe and US is invaluable.  His viewpoint and opinion is his own.


Recently, I attended the Passenger Terminal Expo in Frankfurt, Germany. I spoke with most of the self-check-in kiosk manufacturers and found out that many intend to build only ADA-compliant kiosks in the future. They worried about the risk involved if a wheelchair user caannot immediately find an accessible kiosk, so better make them all ADA.

This raises an important question: Is this approach practical? Should ADA regulations specify a percentage of kiosks that must be wheelchair accessible? Is it discriminatory if a company installs only ADA kiosks?

airline kiosks ada

airline kiosks ada

Consider this scenario:

A visually impaired person who is 6 foot one (1.85 meters) tall is at an airport searching for a self-check-in kiosk. The ADA-compliant kiosk’s screen is set very low, with the Storm ADA interface even lower. The ticket and bag tag printers are nearly at ground level (seen in real life at the Passenger Terminal Expo in Frankfurt).

Nowadays, most kiosks at ADA height have a Storm interface or other tactile/voice/sound input/output possibilities, but standard height ones do not. Again, a tall visually impaired person might not be happy. Isn’t this discriminatory towards a visually impaired person?

A few statistics:

50% of the U.S. population is over 1.68 meters tall and 25% are over 1.75 meters tall. For all these people, whether disabled or not, using a low kiosk is uncomfortable.

My Call for AIA!!!

I advocate for the Americans Inclusion Act (AIA), which would ensure that self-service devices are designed for all people. It shouldn’t be permissible to have kiosks set only at wheelchair height. There should be a rule specifying what percentage of kiosks should be at ADA height and what percentage at standard height.

Ergonomics at the Workplace

Over decades, workplace ergonomics have evolved and, in some cases, been codified into regulations or laws. Why should these principles be ignored for self-service kiosks?

An ADA kiosk is currently uncomfortable for the average person or at least for 25-50% of the population. Therefore, a “one size fits all” approach is not practical; we need kiosks at two different heights.

Neck Problems in Younger Generations Due to Smartphone Use

Studies show that younger generations are developing neck problems from looking down at their phones. We are repeating this with ADA kiosks and tilted screens, requiring users to look down. The only ergonomically correct and comfortable way is to look straight at a vertical screen, or if tilted, at a comfortable height.

Height-Adjustable Kiosks as an Alternative?

This seems like a good theoretical solution. It meets ADA legal requirements, but in practice, it may fall short. Self-service kiosks aim to increase efficiency and customer flow, so they need to be quick to use.

Height-adjustable kiosks, like adjustable desks, are usually motorized. Imagine standing in line, waiting as each person adjusts the height (cue motor noise). Waiting 10 seconds can feel like an eternity. And what are the additional costs of these height-adjustable kiosks?

The Department of Transportation (DOT) and Airports:

Interestingly, the Department of Transportation (DOT) already mandates that at least 25% of all kiosks in airports be accessible. This higher percentage ensures better accessibility and reduces wait times for individuals with disabilities. So, why doesn’t ADA make similar clear requirements for all environments?

Conclusion:

A one-size-fits-all concept is impractical. Dear manufacturers, please don’t offer your clients only ADA-compliant kiosks. That has nothing to do with ergonomics!

Recommend a certain percentage of ADA kiosks and make some kiosks at standard height with a convenient Storm ADA interface – 50% of visually impaired people over 1.68 meters will thank you. To the ADA committee, please specify in your guidelines what percentage of kiosks at a location should be wheelchair accessible. The term “sufficient” is not specific enough.

Comments Welcomed – Discussion is a Good Thing

  • Seriously, the old adage I hear thrown around all the time is “tall people can bend down”. At 6’-1” I’m not super tall, but tall enough that ADA compliant Kiosks are often hard to use. I recall being in Italy last summer and using a Kiosk set way above ADA and thinking how luxurious it was to not bend over. But I also think that way about tall showers, taller bathroom counter tops and the like. This world is not well tailored to the tall. Frank Olea
  • I do believe one size can fit all when Universal Design Principles are applied at the concept phase of development. And I don’t think pushing a button to adjust the height of a kiosk would critically impact the queue time, it’s a matter of seconds not minutes. The idea though, that the solution is modification instead of innovation, is what gets us stuck. What if a kiosk sensed the position of the user? Possibilities open up when the design is based on the user experience with full inclusion at the beginning. Also, I feel like percentages [what percent of kiosk should be ADA] is a futile discussion, there will never be consensus. Moreover, how is it an equitable experience when a user has to hunt for the kiosk that will “work” for them? Will there be kiosks for people using wheelchairs and those who are short, a few for people with sight loss, and then some for tall people too? Imagine if spell check was only available on two of the office computers! Universal Design benefits everyone.  MJ Barry, Dolphin Computer Access
  • Craig Keefner — Seems like always exceptions. One of the complaints about the Little Clinic check-in kiosks is that some find them too short. This is Colorado and maybe people are higher than the base the ADA standards used (5 foot 4″ is my guess but I will check.
  • Craig Keefner — Philippe Boileau With increased use of cameras many have to crouch to get in focus. Eye level for a woman at 64″ still has to “reach” down to the 48 (or 44) max. I understand the most good for the most people but the min/max parameters still have problems. THere are short urinals in bathrooms but not all of them are short. The 48 reach is generally derived from person in wheelchair extending arm. Also consider less than 3% of US public uses a wheelchair. Its a tough equation no matter how you view it.
  • Frank Olea — Is it at all possible that ADA compliant kiosks are not inclusive to tall

    Patient Check-in Kiosk with Riser for Elevated Height

    Patient Check-in with Riser for Elevated Height

    people? I’m 6’-1” and when I stand in front of my own product I have to stoop and I’m not really “tall”. We build this check in kiosk for a very large healthcare chain and they got complaints from taller patients, so they had us make a riser for some of the kiosks that go out to accommodate taller patients. Christoph Nussbaumer recently wrote an article about it and it started a lot of debate with us Kiosk types.  See image to the right. If I were to guess I would say Kaiser Permanente

  • See Little Clinics in Kroger article. One of the complaints is unit is too short. It is Elo model and it is perfect ADA spec.
  • Thread on Linkedin
  • Chad Behling, PMPView Sr. PMP Certified Project Manager & Program Manager – When I worked at Uber and was helping run kiosk pilots, we utilized a stool for taller people to confortably use the kiosk but the experience was different as they were mostly used for driver onboarding, which took more time than something like check in.
  • Netherlands and Germany are the tallest. https://en.m.wikipedia.org/wiki/Average_human_height_by_country

    average height of wheelchair users

    average height of wheelchair users

Useful Links

Related Links

Bit of Humor Never Hurts

ADA Kiosk Checklist – Draft May 2024

ADA Kiosk Multi-Point Checklist

With the new regulations coming soon this year, KMA has issued a draft revision of its 17 point ADA checklist. Best advice in plain english.

  1. Begin your project updates or initial design phase with accessibility in mind – a developer’s proverb says that you can spend time planning at the beginning or fixing at the end. While you may perform a cost/benefit analysis to guide you, the liability of being inaccessible at this time in history is too great.
  2. Separate the ADA considerations into three parts
    1. Hardware Terminal
    2. Application/Interface
    3. Installation

Hardware: ADA Standards for Accessible Design and ICT Accessibility 508 and 255 Guidelines outline specific requirements for ensuring that kiosks are accessible to people with disabilities.

  1. Reach Ranges – ensure a sitting or standing persons can access the kiosk.
  2. Alternative Navigation and Inputs – operable controls must be tactilely discernible, ex. navigation pad, arrow keys, and other touchscreen alternatives.
  3. Audio Jack – plugging in headphones is the standard action that triggers a speech output mode for users who are blind.

Software: accessibility principles for software state that it must be perceivable, operable, understandable, and robust.

  1. UI/UIX Design – while WCAG 2.2 is the current standard for web accessibility, many of the guidelines can be applied to kiosk software development, paying particular attention to contrast, errors, focus, labels, and target size.
  2. Speech Output Enabled – speech output is required for people with visual impairments, but it also provides ways to support people with other print barriers like dyslexia, low literacy, and language learners.
  3. Mobile Proxy – if leveraging a mobile application as an additional means for making self-service accessible, ensure your app meets WCAG 2.2 guidelines.

Added Hardware Devices: kiosks are integrated solutions, meaning there are often many hardware components working together to create the total self-service experience.

  1. Devices and Components– can the kiosk user complete every task independently? This includes biometric or other authentications, scanning, transactions, cash in and out, etc.
  2. Privacy and Security – confirm a user’s personal information safe when using the kiosk.

Installation: logistical considerations should be made prior to installation

  1. Spacing – depth, clearance, maneuverability, protruding objects.
  2. Light – the position has been assessed in daylight ensuring the screen can be read and also after dark to assess screen lighting.
  3. Sound – can speech output be heard against ambient noise in the location and environment.
  4. Temperature – if the kiosk is in direct sunlight are the controls cool enough to touch.

Testing: Conformance and usability testing are paramount to the success of any kiosk project

  1. Conformance Testing: should be done by independent accessibility experts – there are many organizations, public and private who perform conformance testing.
  2. User Testing – have users with and without disabilities (including deaf and hard of hearing, blind and visually impaired, those with physical disabilities and neurodiversity).

Compliance:

  1. Accessibility Audit Log & Development Milestones– Dolphin strongly recommend companies agree to a full accessibility audit of their software at concept phase of a kiosk development project. In addition to being able to fix known accessibility issues that will create a barrier for accessibility software, organizations who provide accessibility audits will provide you with a log of your accessibility testing outcomes and development targets to provide as proof of intent to comply with accessibility laws to authorities in the case of litigation.

ADA Kiosk Checklist Draft_2024

More Resources

Internal Links

Notes

  • Having an accessibility program, internally, can help address long-term kiosk deployments, employee workstations, your website and and your mobile apps. Too often accessibility is tucked into its own separate silos.  Accessibility can no longer be delegated to a third party in the legal sense.