Guidance by WCAG2ICT on Closed Systems

W3C

WCAG and Closed Systems Guidance

WCAG has always been about the open web.  For closed systems some of WCAG (3 instances) are included in the U.S. Access Board recommendations for closed systems.  In 2013 the W3C issued this same document (but using WCAG 2.0). This is the updated versions for WCAG 2.2.  This document is “guidance” (566 pages) on how WCAG 2.2 can apply to Ebooks, Operating systems, and Travel kiosks (example given). There is no mention of ATMs or hybrid POS SCO systems or POS terminals which would seem to be the majority of closed systems.

We do note there is a specific recommendation for kiosks regarding the timeout period (see below).

It should be noted that the DOJ has issued NPRM regarding Web and Mobile accessibility. In their NPRM they use WCAG 2.1 Level AA which is current release.  It will be different though and not reference WCAG 2.2 .

The committee is still finalizing Appendix A and is accepting comments from any interested parties. We are commenting and if you would like yours included email to [email protected]

Background

Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT), approved in September 2013, described how WCAG 2.0 could be applied to non-web documents and software.

Abstract:

This document, “Guidance on Applying WCAG 2.2 to Non-Web Information and Communications Technologies (WCAG2ICT)” describes how the Web Content Accessibility Guidelines (WCAG) 2.2 [WCAG22] and its principles, guidelines, and success criteria can be applied to non-web Information and Communications Technologies (ICT), specifically to non-web documents and software. It provides informative guidance (guidance that is not normative and does not set requirements).

This document is part of a series of technical and educational documents published by the W3C Web Accessibility Initiative (WAI) and available from the WCAG2ICT Overview.

Editors: (IBM) (Oracle Corporation) (NCR)

Excluded from Scope

The following are out of scope for this document:

  • This document does not seek to determine which WCAG 2.2 provisions (principles, guidelines, or success criteria) should or should not apply to non-web documents and software, but rather how they would apply, if applied.
  • This document does not propose changes to WCAG 2.2 or its supporting documents; it does not include interpretations for implementing WCAG 2.2 in web technologies. During the development of this document, the WCAG2ICT Task Force did seek clarification on the intent of a number of the success criteria, which led to clarifications in the Understanding WCAG 2.2 document.
  • This document is not sufficient by itself to ensure accessibility in non-web documents and software. As a web standard, WCAG does not fully cover all accessibility requirements for non-user interface aspects of platforms, user-interface components as individual items, nor closed product software (where there is no Assistive Technology to communicate programmatic information).
  • This document does not comment on hardware aspects of products, because the basic constructs on which WCAG 2.2 is built do not apply to these.
  • This document does not provide supporting techniques for implementing WCAG 2.2 in non-web documents and software.
  • This document is purely an informative Note about non-web ICT, not a standard, so it does not describe how non-web ICT should conform to it.

Examples of products with closed functionality include:

  • an ebook or ebook reader program 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).
  • an operating system that requires the user to provide login credentials before it allows any assistive technologies to be loaded. The log-in portion would be closed functionality.
  • a travel kiosk that provides an audio interface for blind and vision-impaired users as a built-in alternative to the visual interface and tactile keys as an alternative to touch screen operation for both blind users and those who can’t operate a touch screen.

See Appendix A: Success Criteria Problematic for Closed Functionality for a list of success criteria for which this is relevant.

Timeout Criteria

20 seconds was also based on clinical experience and other guidelines. 20 seconds to hit ‘any switch’ is sufficient for almost all users including those with spasticity. Some would fail, but some would fail all lengths of time. A reasonable period for
requesting more time is required since an arbitrarily long time can provide security risks to all users, including those with disabilities, for some applications. For example, with kiosks or terminals that are used for financial transactions, it is
quite common for people to walk away without signing off. This leaves them vulnerable to those walking up behind them. Providing a long period of inactivity before asking, and then providing a long period for the person to indicate that they are present can leave terminals open for abuse. If there is no activity the system should ask if the user is there. It should then ask for an indication that a person is there (‘hit any key’) and then wait long enough for almost anyone to respond. For “hit any key,” 20 seconds would meet this. If the person indicates that they are still present, the device should return the user to the exact condition that existed before it asked the question.

PDFs

DOJ NPRM On Web and Mobile Accessibility

website accessibility DOJ

Web Accessibility – Mobile Accessibility

Editor Note:  Self-service kiosks and digital signage/interactive displays such as wayfinding for example and smart city are both considered “closed systems”. Websites are considered open systems.  Mobile applications are new and the proposed regulations there are likely to have the most impact

The Department of Justice (Department) is publishing a Notice of Proposed Rulemaking (NPRM) explaining how we propose updating the regulations for Title II of the Americans with Disabilities Act (ADA) to add more specific requirements about web and mobile application (app) accessibility.

This NPRM proposes a specific technical standard that state and local governments would have to follow to meet their existing obligations under Title II of the ADA for web and mobile app accessibility. The NPRM asks the public for comments about this proposal.

Summary In Brief

  • What is Title II?  — Under Title II of the ADA, state and local governments’ services, programs, and activities must be accessible to people with disabilities. In Title II, state and local governments are also called public entities. Title II applies to all programs, services, or activities of state and local governments, from adoption services to zoning regulation. This includes the services, programs, and activities that state and local governments offer online and through mobile apps.WCAG 2.1 Level AA is the adopted standard
  • An NPRM is a stage in the rulemaking process that happens before an agency adopts a final regulation. It is like a first draft of a regulation. It lets the public know what the agency is considering and provides an opportunity for feedback.
  • An NPRM is not a final regulation. So, this proposal is not an enforceable rule right now. This NPRM has been published so that the public can provide us with feedback on our proposal for the rule before we adopt a final rule.
  • Two to Three years to meet standard depending on size (greater than 50,000 has two years)
  • How and When to Respond — We Want Your Feedback
    The fact sheet gives a high-level summary of the NPRM. For more details about our proposal, you should read the NPRM. The NPRM is also published in the Federal Register. We have also published an analysis of the costs and benefits of the proposed rule. This is called a Preliminary Regulatory Impact Analysis (PRIA). You can read the PRIA on ADA.gov. After you’ve reviewed the NPRM, we’d like to hear your feedback. Have we made the right proposals about when and how web content and mobile apps should be made accessible? Do the proposed exceptions and the proposed limits on when those exceptions apply make sense? Should we change anything about the proposed rule? Why? You can submit comments before October 3, 2023 by going to Regulations.gov. You can also mail us your comments at Disability Rights Section, Civil Rights Division, U.S. Department of Justice, P.O. Box 440528, Somerville, MA 02144.
    If you need information in an alternative format, you can call the ADA Information Line at (800) 514-0301 (voice) or 1-833-610-1264 (TTY).
  • Here is a 2023 NPRM web-accessibility-NPRM-compressed

Excerpts

For example, a study from the University of Washington analyzed approximately 10,000 mobile apps and found that many are highly  inaccessible to people with disabilities. 46 The study found that 23 percent of the mobile apps reviewed did not provide content description of images for most of their image-based buttons. As a result, the functionality of those buttons is not accessible for people who use screen readers. 47

Mobile Applications
The Department is proposing to adopt the same technical standard for mobile app accessibility as it is for web content—WCAG 2.1 Level AA. As discussed earlier, WCAG 2.1 was published in June 2018 and was developed, in part, to address mobile accessibility. 105
The Department considered applying WCAG 2.0 Level AA to mobile apps, which is a similar approach to the requirements in the final rule promulgated by the United States Access Board in its update to the section 508 standards. 106 WCAG 2.1 was not finalized when the
Access Board adopted the section 508 standards. When WCAG 2.0 was originally drafted in 2008, mobile apps were not as widely used or developed. Further, the technology has grown considerably since that time. Accordingly, WCAG 2.1 provides 12 additional Level A and AA
success criteria not included in WCAG 2.0 to ensure, among other things, that mobile apps are more accessible to individuals with disabilities using mobile devices. 107 For example, WCAG 2.1 includes Success Criterion 1.4.12, which ensures that text spacing like letter spacing, line spacing, and word spacing meets certain  requirements to ensure accessibility; Success Criterion 2.5.4, which enables the user to disable motion actuation (e.g., the ability to activate a device’s function by shaking it) to prevent such things as accidental deletion of text; and Success Criterion 1.3.5, which allows a user to input information such as a name or address W3C®, What’s New in WCAG 2.1 (Aug. 13, 2020), https://www.w3.org/WAI/standards-guidelines/wcag/new-in-21/ [https://perma.cc/W8HK-Z5QK].
106
See 82 FR 5790, 5815 (Jan. 18, 2017).
107
W3C®, What’s New in WCAG 2.1 (Aug. 13, 2020), https://www.w3.org/WAI/standards-guidelines/wcag/new-in-21/ [https://perma.cc/W8HK-Z5QK].
105automatically. 108
The Access Board’s section 508 standards include additional requirements applicable to mobile apps that are not in WCAG 2.1, and the Department is requesting feedback on whether to adopt those requirements as well. For example, the section 508 standards apply the following requirements not found in WCAG 2.1 to mobile apps: interoperability requirements to ensure that a mobile app does not disrupt a device’s assistive technology for persons with disabilities (e.g., screen readers for persons who are blind or have low vision); requirements for mobile apps to follow preferences on a user’s phone such as settings for color, contrast, and font size; and requirements for caption controls and audio description controls that enable users to adjust caption and audio description functions. 109 Adopting WCAG 2.1 Level AA for mobile apps will help ensure this rule’s accessibility standards for mobile apps are consistent with this rule’s accessibility standards for web content. We seek comments on this approach below. Please provide as much detail as possible and any applicable data, suggested alternative approaches or requirements, arguments, explanations, and examples in your responses to the following questions.

Related Posts

Related Accessibility Standards

As a refresher her are the main illustrations from U.S. Access Board on common physical characteristics of self-service kiosks. Bear in these only show the physical and not all of them either.

NPRM Proposed Rule Web and Mobile App Access

website accessibility DOJ

Justice Department Advances Proposed Rule to Strengthen Web and Mobile App Access for People with Disabilities

Tuesday, July 25, 2023

For Immediate Release
Office of Public Affairs
The Justice Department sent to the Federal Register for publication a notice of proposed rulemaking under Title II of the Americans with Disabilities Act (ADA) that aims to improve web and mobile applications (apps) access for people with disabilities and clarify how public entities – primarily state and local governments – can meet their existing ADA obligations as many of their activities shift online.

Across the United States, people routinely rely on web and mobile apps to access a variety of vital public programs and services like employment and educational resources, voting information, health and emergency services, parking, and transit schedules. The proposed rule is particularly significant in the wake of the pandemic, as public entities have significantly increased the scope of essential services and programs offered through the web and mobile apps. It is critical for these technologies to be accessible for people with disabilities.

“This marks the first time in the history of the Americans with Disabilities Act that the Justice Department has issued a proposed rule on website accessibility,” said Attorney General Merrick B. Garland. “This proposed rule seeks to ensure that Americans with disabilities have equal access to the websites and apps that connect them to essential services provided by state and local governments.”

“This proposed rule, which is the culmination of years of work and collaboration, is a historic moment for the Justice Department,” said Associate Attorney General Vanita Gupta. “It will help enshrine the right of Americans with disabilities to access critical information needed to lead safe, productive, and prosperous lives.”

“This proposed rule marks a significant milestone in the Justice Department’s efforts to advance accessibility in the digital sphere,” said Assistant Attorney General Kristen Clarke of the Justice Department’s Civil Rights Division. “This groundbreaking moment makes clear our commitment to eradicating the barriers faced by people with disabilities and affording equal access to online government programs and services that people around the country depend on every day. We will continue to use every tool available to ensure that people with disabilities are provided full access to the digital town square.”

As state and local governments continue to move more of their programs and activities online – from applying for permits to checking the status of service requests, registering vehicles, and paying taxes and fees – ensuring that people with disabilities have equal access to these same services is essential. When websites and mobile apps are not accessible, they can be difficult or even impossible for people with disabilities to use. This can block people with disabilities from readily accessing important government services and programs that others can quickly and easily obtain online.

The Department is eager to hear from the public and get input from relevant stakeholders on the regulatory proposal set forth in our forthcoming proposed rule. The proposed rule will soon be available for review on the Federal Register’s website at www.federalregister.gov. A fact sheet that provides information about the proposed rule will soon be available on www.ada.gov. The Department invites the public to submit their comments on the proposed rule once it is published. The comment period will be open for 60 days from the date the proposed rule is published. Public comments can be submitted on www.regulations.gov.

For more information on the Civil Rights Division, please visit the Department’s website. For more information on the ADA, please call the Department’s toll-free ADA Information Line at 800-514-0301 (TDD 800-514-0383) or visit the ADA website.

Updated July 25, 2023

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Resource Posts

Screen Reader Software – Vispero listed now on AWS Marketplace

JAWS Kiosk

Vispero/TPGi Listed in AWS Marketplace for the U.S. Intelligence Community

Couple of news items for screen reader news, both from Vispero, the leader with JAWS Kiosk software. From PRnewswire — Vispero/TPGi Software now available to 18 U.S. Intelligence Agencies in AWS Marketplace

JAWS Kiosk AWS Marketplace

JAWS Kiosk AWS Marketplace

CLEARWATER, Fla., June 7, 2023 /PRNewswire/ — Vispero® and TPGi®, global leaders in accessibility software and services, today announced the availability of their offerings in the AWS Marketplace for the U.S. Intelligence Community (IC). The AWS Marketplace for the U.S. IC offerings includes a broad array of common software infrastructure, developer tools, and business software products that support the unique needs of the U.S. IC through improved security, increased mission impact, and cost savings. TPGi’s Accessibility Resource Center (ARC) software allows companies of all sizes to manage accessibility programs via one powerful integrated dashboard and to access a central repository of over 600 KnowledgeBase articles from worldwide experts in accessibility.

“We are pleased to offer our software in the AWS Marketplace for the U.S. IC to help government agencies assure their digital assets are usable by all employees and citizens while complying with Section 508 and accessibility standards,” said Matt Ater, Vice President of Vispero.AWS Marketplace for the U.S. IC provides the same purchasing convenience, open and transparent license terms and conditions, and a variety of pricing models, including hourly usage and annual subscription, as the commercial AWS Marketplace. It also supports Bring-Your-Own-License (BYOL) so that agencies can more easily migrate existing software licenses and applications to the cloud. For more information on AWS Marketplace for the U.S. IC, contact [email protected].

About Vispero

Vispero is a global leader in assistive technology products for those with vision impairments. Freedom Scientific, TPGi, Enhanced Vision, and Optelec, all Vispero brands, have a long history of innovation for customers with accessibility needs. Today our product portfolio is considered one of the most diverse and reliable on the market.

About TPGi

TPGi provides digital accessibility software and services to help businesses reduce risk, grow revenue, and improve user experience. With over 20 years of experience and 21 employees actively influencing accessibility standards on the World Wide Web Consortium (W3C), TPGi offers the most robust knowledge base and accessibility expertise in the industry as well as award-winning self-service kiosk software. Our tailored approach has enabled 1000+ customers to achieve the best outcomes for their businesses, their employees, and their consumers.

SOURCE TPGi LLC

Disability:IN show in Orlando in July

jaws kiosk

jaws kiosk

Join Vispero® and TPGi at the #DisabilityInclusion event of the year. You can stop by our booth and check out Matt Ater speak during “Creating A Culture Beat: Drumming Up Support for Digital Accessibility.”

We can’t wait to meet you there!

Learn more about Disability:IN 2023: https://lnkd.in/gEBhNDWT

JAWS Kiosk Brochure Digital 2022-compressed

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ADA Regulations for EV Vehicles, Self-Service Kiosks & POS

ADA Regulations

ADA Regulations Update June 2023

June 15, 2023 — New updated dates for US Access Board NPRMs for EV and POS. Also, ANSI has just released their new EV standards, which include ADA considerations.  Thanks to Steve Taylor with TaylorPOS for reminding us of the NPRM dates.

Accessibility Guidelines for Self-Service Transaction Machines

This rulemaking would amend the Architectural and Transportation Compliance Board’s existing accessibility guidelines for buildings and facilities under the Americans with Disabilities Act (ADA) and the Architectural Barriers Act (ABA), located at 36 CFR part 1191, to include guidelines for the accessibility of fixed self-service transaction machines, self-service kiosks, information transaction machines, and point-of-sale devices.  The U.S. Department of Transportation and U.S. Department of Justice are expected, via separate rulemakings, to adopt these amended guidelines as enforceable standards for devices and equipment covered by the ADA. RIN: 3014-AA44

Timetable:

ACTION DATE FR CITE
ANPRM 09/21/2022 87 FR 57662
ANPRM Comment Period End 11/21/2022
NPRM 12/00/2023

Accessibility Guidelines for Electric Vehicle Charging Stations

Electric vehicle (EV) charging stations are becoming commonplace with the rising production and use of electric and plug-in hybrid vehicles.  According to the U.S. Department of Energy, there are nearly 50,000 public EV charging stations with almost 127,000 charging ports across the country.  The Infrastructure Investment and Jobs Act, signed into law in November 2021, allocates $7.5 billion to construct a national network of 500,000 EV charging stations to accelerate the adoption of EVs.  It is expected that the installation and use of EV charging stations will continue to expand; however, at present, there are no federal regulations specifying accessibility requirements for EV charging stations to ensure that they are accessible to and useable by persons with disabilities. The Access Board thus intends to publish a notice of proposed rulemaking to supplement its Accessibility Guidelines under the Americans with Disabilities Act (ADA) and Architectural Barriers Act (ABA) with scoping and technical requirements for electric vehicle charging stations. RIN: 3014-AA48

Timetable:

ACTION DATE FR CITE
NPRM 07/00/2023

ANSI Publishes Roadmap of Standards and Codes for Electric Vehicles at Scale

New York, June 14, 2023: The American National Standards Institute (ANSI) announced today the publication of the Roadmap of Standards and Codes for Electric Vehicles at Scale developed by the Institute’s Electric Vehicles Standards Panel (EVSP). The roadmap’s primary focus is on light-duty, on-road plug-in electric vehicles (EVs) that are recharged via a connection to the electrical grid, as well as the supporting charging infrastructure needed to power them. Medium and heavy-duty EVs are also covered, as is wireless charging. A total of 37 standardization gaps are identified with corresponding recommendations across the topical areas of vehicle systems, charging infrastructure, grid integration, and cybersecurity. It is hoped that the roadmap will see broad adoption by the user community and will facilitate a more coherent and coordinated approach to the future development of standards for EVs.

The Kiosk Manufacturer Association (KMA) is an Associate Sponsor. (UL is the premier sponsor)

ADA Excerpt:

(c) The American with Disabilities Act of 1990 (ADA), and implementing regulations, apply to EV charging stations by prohibiting discrimination on the basis of disability by public and private entities. EV charging stations must comply with applicable accessibility standards adopted by the Department of Transportation into its ADA regulations (49 CFR part 37) in 2006, and adopted by the Department of Justice into its ADA regulations (28 CFR parts 35 and 36) in 2010. 45 The U.S. Access Board, an independent federal agency that issues accessibility guidelines under the Americans with Disabilities Act(ADA), Architectural Barriers Act(ABA), Rehabilitation Act of 1973, and other laws, has provided a technical assistance document “Design Recommendations for Accessible Electric Vehicle Charging Stations” 46 to assist in the design and construction of electric vehicle (EV)
charging stations that are accessible to and usable by people with disabilities. In the Fall 2022 Unified Agenda and at recent Board Meetings, the Access Board announced that it anticipates a Notice of Proposed Rulemaking (NPRM) for EVSE towards the end of the summer of 2023. Noting the expected continuing expansion and use of EV charging stations, the Board noted in relevant part that: [T]here are no federal regulations specifying accessibility requirements for EV charging stations to ensure that they are accessible to and useable by persons with disabilities. The Access Board thus intends to publish a notice of proposed rulemaking to supplement its Accessibility Guidelines under the Americans with Disabilities Act (ADA) and Architectural Barriers Act (ABA) with scoping and technical requirements for electric vehicle charging stations.

47 44 https://www.federalregister.gov/d/2023-03500/p-385 45 https://www.federalregister.gov/d/2023-03500/p-465 46 The Access Board, “Design Recommendations for Accessible Electric Vehicle Charging Stations” last updated 7/21/2022, Accessed 3/13/2023 https://www.access-board.gov/tad/ev/ 47 The Access Board, “Accessibility Guidelines for Electric Vehicle Charging Stations,” RIN: 3014-AA48, Fall 2022,Accessed 2/13/2023 https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202210&RIN=3014-AA48
ANSI EVSP Roadmap of Standards and Codes for Electric Vehicles at Scale Page 101 of 170

The DOE Clean Cities Coalition Network provides best practices for installing ADA-compliant EV charging stations. 48
In addition, the California Division of the State Architect has developed accessibility requirements for EV charging, which are part of the California Building Code. 49
The 2021 International Building Code® (IBC®), section 1107, provides that no less than 5% of vehicle spaces at an EV charging site, and not fewer than one space for each type of EV charging system, shall be accessible. 50 This is not required for R-2, R-3, and R-4 occupancies. In terms of standards activity, ICC A117.1—2017 Accessible And Usable Buildings And Facilities, section 502.11, provides requirements that EV charging stations comply with requirements for operable parts (card readers) and are free of obstructions between the charging station and the adjacent parking space. 51 As noted, there is some policy activity anticipated. At this time, no codes and standards gap has been identified.

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Patient Kiosk Demo from HIMSS With ADA

ADA Kiosk Storm

Healthcare Kiosk Demo

Published on Healthcareittoday.com – Author John Lynn

In Brief

  • Nicky Shaw US Operations Manager at Storm Interface  does the demo
  • demonstration of accessibility device as part of check-in kiosk
  • Inability to use the touchscreen is the benefit
  • Kiosk has an Storm Audiopad installed on kiosk by Kiosk Innovations with screenreader software by Vispero (JAWS Kiosk)
  • Audio and Tactility are the key features
  • Demo done at HIMSS 2024
  • A second kiosk by Pyramid America part of demo

Excerpt:

One of the most interesting opportunities at the HIMSS annual conference is the chance to see demos of a wide variety of health IT solutions.  At this year’s event, we decided to film a number of demos of interesting health IT products that we thought readers of Healthcare IT Today would find useful.  If you want to see all of these demos as we share them, be sure to subscribe to the Healthcare IT Today YouTube channel.

The first demo I’m excited to share is by Nicky Shaw, US Operations Manager at Storm Interface.  Shaw demonstrates how you can take a healthcare kiosk and make it accessible for those who may have visual or other impairments.

Listen and subscribe to the Healthcare IT Today Interviews Podcast to hear all the latest insights from experts in healthcare IT.

Video Demo

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Quarterly Review of Legal Decisions Regarding Accessibility – 2023

ADA Kiosks Legal Action Kiosks

This page on legal actions in self-service and related is a running log with personal commentary on legal, privacy and patent situations which impact unattended self-service.  We keep track of legal news that affects the unattended self-service market.  One of the best articles to monitor is Kiosk Accessibility: The Law is Paying Attention by Lainey Feingold. Another great source is Understanding The ADA blog by William Goren.

Legal actions can also be HIPAA violations of privacy data and also web accessibility (WCAG usually), which have financial and legal consequences.  If you have news of note send us an email at [email protected]

Notable Legal Actions and Related In Brief:

  • Apr 2023
    • Biometrics and Illinois – Christian Dior’s virtual “try on” glasses wins in Illinois under BIPA and facial recognition. Link
    • ADA Tester of Hotels SCOTUS to rule on — In the court papers, Acheson’s lawyers claimed that Laufer had filed over 600 lawsuits since 2018 targeting small hotels and bed and breakfasts and that the cost of litigating a case might put defendants into bankruptcy. “A cottage industry has arisen in which uninjured plaintiffs lob ADA lawsuits of questionable merit while using the threat of attorney’s fees to extract settlement payments,” Acheson’s lawyers said.
  • Mar 2023
  • Feb 2023
    • CVS and Dalton –– CVS class action claims blind, low-vision customers cannot independently use HealthHub kiosks. CVS Health Corporation failed to make its CVS HealthHub self-service kiosks independently usable for individuals who are blind or visually impaired, a new class action lawsuit alleges.  Dalton vs. CVS Lawsuit Brief — Here are some pictures of Healthhub kiosks which are basically cheap mounted tablets. LINK
    • Biometrics and Maryland — link on Biometric Update – State of Maryland legislators are debating five bills (four cross-filed and one separate) addressing biometric and other private data collected by private organizations as part of doing business. Members of the Computer & Communications Industry Association issued a statement saying any legislation needs to be narrowly written to protect “high-risk practices,” although without spelling out what that means.
    • Employees, Biometrics & Fingerprints — White Castle facing a fine of $17B for violating privacy of employees with fingerprint scanner. On February 17, 2023, the Illinois Supreme Court held that each scan or transmission of a person’s biometric identifiers is a separate violation of Illinois’ Biometric Information Privacy Act (BIPA). In Cothron v. White Castle System, Inc., 2023 IL 128004, the plaintiff was an employee at a White Castle restaurant. She alleged that White Castle, without obtaining the statutorily mandated consent, required her to scan her fingerprint multiple times each day to access company systems. The plaintiff argued that each scan since BIPA’s enactment in 2008 was a separate violation. White Castle argued that if any violation occurred, it was a single violation in 2008, when it first collected her fingerprints without obtaining proper consent. Thereafter, White Castle argued, each new scan was not a new “collection” of her fingerprints. By a 4-3 majority, the court agreed with the plaintiff that each scan was a separate violation. National Law Review, White Castle could face multibillion-dollar judgment in Illinois privacy lawsuit,
    • Related:  Repeated Violations Doctrine
    • Nearly 2,000 lawsuits alleging violations of BIPA have been filed since 2017, yielding a series of massive settlements and judgments. Amazon, Facebook and others.
  • January 2023
    • Voice Recognition — Whole Foods Reaches $300k BIPA Settlement Over Voice Recognition Lawsuit — Whole Foods has reached a $297,000 settlement in a lawsuit filed under Illinois’s Biometric Information Privacy Act (BIPA). The lawsuit alleged that Whole Foods enrolled distribution center workers in a voice recognition system without properly obtaining consent and providing the necessary disclosures as required under BIPA. The settlement, which has received early approval from a state court judge, would see $545 paid out to each of the class action’s 330 workers.

ADA – Whole Foods SCO Review

Amazon Whole Foods Self-Service

We shop at Whole Foods from time to time. Part of our Costco-WholeFoods equation.

Seemed like a good time to “check out” the SCO there and the return lockers.

Notes on the SCO

  • Modified unit from NCR (same as Walmart)
  • No cash (unlike Walmart)
  • We didn’t have a chance to test while in wheelchair and do the measurements.
  • They have an “Accessibility Mode” which you can select but other than bring up the diamond navigation there is no audio. Perhaps there is a headphone jack we missed.
  • The diamond nav does tab between interface options but there was no audio. There is an audio button and we made sure volume all the way up but nothing.
  • Additional Comments by TaylorPOS —
    • The measurements matter but reach and range (only) are what have been the very problems forever.   Those NCR’s POS readers are way out of use for wheelchairs and highly probable for a lot of little people.
    • It also does not comply with PCI-POI (“must be able to PIN shield using the body”.  As well as ADA 302.8 limited reach and strength and 508 (ICT) 302.2 aka: ADA Visual Accommodation.
    • Seriously, these mfg’s and businesses including IT dept are just clueless to accessibility being correctly provided.
    • The reasons for ADA 309 and 309.4 are in place for very good reasons.
  • Comments from accessibility expert
    • That NCR SCO is a really poor example of how to tackle accessibility isn’t it??! If I had a ‘rogues gallery’ of horribly designed SCOs, I’d be adding that to it. I saw KIS’s returns kiosk at the NRF Show and it looked really slick, I must start looking out for them. I haven’t been to a Whole Foods for a while, but maybe I’ll stop by one when I’m out and about at the weekend.
  • Comments from NCR
  • Comments from Whole Foods

 

Whole Food Self-Check Out SCO

Whole Food Self-Check Out SCO

 

 

The Drop Off Return Locker

  • Nice unit and it was very busy.
  • Returning multiple items took very few minutes.
  • Seemed like some customers tried to open locker before time
  • We watched multiple customers and given the “Pick you Satisfaction” level review at the end they all opted for Very Satisfied.
  • Eventually the locker ran out of space and took itself offline.
  • Definitely free’s up the customer service people to deal with other issues
  • See full post on Amazon Dropoff and Return Lockers
amazon drop off locker

click for full size – amazon drop off locker

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VISA Swipe Fees up 180% – Advocate for Reform

NRF Swipe Fee Reform

Small business is by far the hardest hit since they are the lowest volume. Rates went up 26% in the last 12 months and 180% over the last decade.  Monopolies do not exist for the benefit of consumers and lower inflation. Visa and Mastercard, which control 80 percent of the U.S. credit card market, centrally price-fix the swipe fees charged by banks that issue their cards even though many legal experts say the practice violates federal antitrust law.

Example case

“As the use of credit cards has become more and more prevalent, the credit card companies are making more and more money from merchants. When we first opened our business, credit card transactions accounted for approximately 40 percent of our business. Now the credit card share is about 80 percent of transactions. At the same time, fees have risen and the time taken before funds appear in our accounts gets longer. This is one more burden for merchants.”
John Morman, owner of Celtic Tides gift shop, Lexington, Va.

2023 NRF Small Business Fly-in
July 11-12, 2023
Grand Hyatt, Washington, D.C.

The National Retail Federation is convening 50 small retailers in Washington, D.C., at the 2023 Small Business Fly-in on July 11-12, 2023. Attendees will focus on improving competition in the credit card payments system for retailers. They will learn about legislation and regulatory processes to address payments competition and share their stories directly with lawmakers. Attendees will be able to connect with fellow small retailers from across the country.

We encourage small businesses to sign up to advocate with us. NRF is pleased to be able to provide a limited number of travel scholarships to cover transportation and lodging for selected small business owners. Apply today using our application link. The application closes April 28, 2023.

Why attend?

Attendees will advocate for swipe fee reform and encourage Congress to support the Credit Card Competition Act (CCCA). This bipartisan bill will address the broken and unfair credit card market that’s currently dominated by two major players that set the fees and terms with which all merchants must comply. Lack of competition means credit card swipe fees continue to rise year after year, soaring 25% last year alone.

The bipartisan Credit Card Competition Act would infuse competition into the marketplace by simply requiring there be at least two competing processing networks enabled on each credit card. These reforms have the potential to save American businesses and consumers an estimated $11 billion per year.

We are convening small retailers to share their stories on how excessive swipe fees stifle growth and expansion for small businesses and make it difficult to invest in their companies by hiring more staff, buying more inventory, competing on price and even keeping their doors open in today’s uncertain and inflationary economic climate.

 I hope you’ll consider applying today. If you have any questions, don’t hesitate to contact me.

Sincerely,

Meghan Cruz
Senior Director, Grassroots Advocacy
National Retail Federation
Direct: 202-626-8151
Cell: 937-474-3824

NRF forecasts 2023 retail sales will grow between 4% and 6% reaching more than $5.13 trillion. Learn more.

ANSI Roadmap for Electric Vehicles Released for Comment

ADA Regulations

ANSI EV Standards and Codes Draft Released

New York, March 31, 2023: The American National Standards Institute (ANSI) released today for public review and comment a draft of the Roadmap of Standards and Codes for Electric Vehicles at Scale developed by the Institute’s Electric Vehicles Standards Panel (EVSP). The roadmap identifies key safety, performance, and interoperability issues; notes relevant published and in-development standards; and makes recommendations to address gaps in codes and standards. This includes recommending pre-standardization research and development (R&D) where needed. It also proposes prioritized timeframes for when standardization work should occur and standards developing organizations (SDOs) or others that may be able to lead such work. Working groups have been developing the draft roadmap since a kickoff event held in June 2022.

Comments Invited by May 1, 2023

The request for comment specifically invites comments that represent critical revisions and needed clarifications on the roadmap content. Comments on the draft roadmap may be submitted to [email protected] by close of business on Monday, May 1, 2023. Use of the comment form (see below) is required to better manage and review comments. The EVSP working groups are currently on hiatus and will reconvene in May to address the comments submitted and finalize the document for publication by the end of June 2023. While all comments are welcome, the EVSP reserves the right to hold disposition of comments in reserve for a future iteration of the document if they cannot be addressed within the time available. This might include, for example, comments on the document’s organization, or issues not addressed.

The draft roadmap and related materials may be downloaded as follows:

Building on ANSI EVSP roadmaps developed in the 2011-14 timeframe, the draft document seeks to describe the current and desired future standardization landscape that will support and facilitate EVs at scale. The roadmap’s primary focus is on light duty, on-road plug-in electric vehicles (PEVs) that are recharged via a connection to the electrical grid, as well as the supporting charging infrastructure needed to power them. Medium and heavy-duty EVs are also covered. Topics covered include standards to address high power DC charging, storage (i.e., microgrid, distributed energy resource management systems) integrated with DC charging, vehicle grid integration, high power scalable/interoperable wireless charging, and vehicle-oriented systems. The broad target audience includes vehicle manufacturers, entities that will be installing and operating charging infrastructure; SDOs; U.S. federal, state, and municipal government agencies; electric utilities; and others.

To advance the Biden Administration’s goal for a clean energy future, the U.S. Department of Energy (DOE) Office of Energy Efficiency & Renewable Energy (EERE) Vehicle Technologies Office (VTO) issued a June 2021 lab call funding opportunity announcement. The lab call included a pillar on codes and standards with the goal to “identify and address challenges and barriers to the integration of EVs@Scale charging with the grid created by uncoordinated development of codes and standards and the rapid advances in vehicle and charging technologies.” An EVs@Scale lab consortium was formed in response with Argonne National Laboratory (ANL) as the lead lab for the codes and standards pillar supported by other national labs. The consortium committed to develop a 2022 roadmap like earlier roadmaps developed by the ANSI EVSP.

The EVs@Scale effort supports funding initiatives associated with deploying a nationwide EV charging infrastructure, including the National Electric Vehicle Infrastructure (NEVI) Formula Program, which provides $5 billion in Federal money to that end. As part of the Bipartisan Infrastructure Law, the Federal Highway Administration was directed to release a set of minimum standards and requirements for the implementation of the NEVI program. The NEVI Final Rule was issued on February 28, 2023, and appropriate references are included in the EVSP roadmap.

ANSI serves as administrator and coordinator of the U.S. private-sector voluntary standardization system. As a neutral facilitator, the Institute has a successful track record of convening stakeholders from the public and private sectors to define standardization needs for emerging technologies and to address national and global priorities. The ANSI EVSP is a cross-sector coordinating body whose objective is to foster coordination and collaboration on standardization matters among public- and private-sector stakeholders to enable the safe, mass deployment of electric vehicles and associated infrastructure in the United States with international coordination, adaptability, and engagement.

The ANSI EVSP does not develop standards. Rather, it serves as a forum for facilitating coordination among SDOs and others. ANSI’s facilitation of the EVSP is partly supported by VTO/ANL and UL Standards & Engagement.

“Standards and related conformity assessment programs have an important role to play in advancing electric vehicle technologies. ANSI invites all affected stakeholders, regardless of geographic location, to review the draft roadmap and make their views known,” said S. Joe Bhatia, ANSI president and CEO.

For more information, visit the EVSP webpage www.ansi.org/evsp or reach out to ANSI staff: Jim McCabe, senior director, standards facilitation ([email protected]; 212-642-8921), or Christine Bernat, associate director, standards facilitation ([email protected]; 212-642-8919).

About ANSI

The American National Standards Institute (ANSI) is a private non-profit organization whose mission is to enhance both the global competitiveness of U.S. business and the U.S. quality of life by promoting and facilitating voluntary consensus standards and conformity assessment systems, and safeguarding their integrity. Its membership is comprised of businesses, professional societies and trade associations, standards developers, government agencies, and consumer and labor organizations.

The Institute represents and serves the diverse interests of more than 270,000 companies and organizations and 30 million professionals worldwide. ANSI is the official U.S. representative to the International Organization for Standardization (ISO) and, via the U.S. National Committee, the International Electrotechnical Commission (IEC). For more information, visit www.ansi.org.

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Kiosk Industry participates in three of the EV working groups and has assisted in development.

The KMA Kiosk Manufacturer Association is an Associate Sponsor of the ANSI EV Committee

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