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1NCR ConfidentialNCR Confidential
The ADA “Final Rule”
September 15, 2010: U.S. Department of Justice published final
regulations revising its 1991 ADA Title III regulations, including its ADA Standards for Accessible Design (the “1991 Standards”).
The 2010 Standards for Accessible
Design (the “2010 Standards”) will become Law March 15, 2011.
2010 Standards: Newly mandated communication related auxiliary aids and services. Exception: fundamental alteration to the public accommodation’s
program or undue burden.
2NCR ConfidentialNCR Confidential
The ADA “Final Rule” ...continued
Undue Burden: defined as "significant difficulty orexpense." It is evaluated on a case-by-case basis, relative to the business’s overall resources
FIs seek legal guidance
NCR work with FI’s Compliance Team
Must provide another communication aid or service that still is effective but is less difficult or costly, if one is available.
3NCR ConfidentialNCR Confidential
Height and Reach
Forward or side reach (2010): High 48 inches Low 15 inches
SelfServ ATMs
Personas ATMs
Will not have to be lowered to meet the 48” max reach range for a side approach until it’s altered!
Legal Guidance alterations trigger 2010 standards?
4NCR ConfidentialNCR Confidential
Height and Reach ...continued
Operable Parts: “A component of an element used to insert or withdraw objects, or to activate, deactivate, or adjust the element.” Highest Operable Part on each ATM model is different.
See: Site Preparation Documentation Touchscreen can be H.O.P. 3rd Party Applications
SelfServ ATMs
Personas ATMs
Shall be placed within one or more of the reach ranges
5NCR ConfidentialNCR Confidential
Privacy
Advisory Note: people who use wheelchairs or have short stature, who cannot effectively block the ATM screen with their bodies, may prefer to use speech output “blank screen” functionality
NCR APTRA Advance NDC
NCR APTRA Edge
Included in the 3.02 release as a standard feature & will be available as a patch upgrade
6NCR ConfidentialNCR Confidential
Speech Output
2010 Standard Requirement: Machines shall be speech enabled
NCR APTRA Edge “Text-to-Speech”
• Multi-Vendor Environment Professional Services
NCR APTRA Advance NDC “Text-to-Speech”• Nuance RealSpeak Solo TTS
7NCR ConfidentialNCR Confidential
Input Controls & Numeric Keys
Input Controls Numeric Keys
• Key surfaces shall be raised above surrounding surfaces
• Tactilely discernable
• Keys shall be arranged in a 12-key ascending or descending keypad layout
• Number 5 key shall be tactilely distinct
SelfServ ATMs Personas ATMs
8NCR ConfidentialNCR Confidential
Function Keys
Contrast Visually? YES! The “Keyboard” issue
SelfServ ATMs Personas ATMs
Safe Harbor
9NCR ConfidentialNCR Confidential
Display Screen
SelfServ ATMs
Personas ATMs
40 3/16
Inches above the center of the clear floor space
Inch high minimum based on the uppercase letter “I”
10NCR ConfidentialNCR Confidential
Braille Instructions
Example Voice Guidance Braille Label
“"Headphone Jack Below" is nothing more than a label that does not convey the required instructions”
~ Marsha Mazz, U.S. Access Board
2010 Standard Requirement: Braille Instructions for initiating speech mode shall be provided.
SelfServ ATMs Personas ATMs
11NCR ConfidentialNCR Confidential
Additional Resources
Each ATM operator should get qualified legal advice from their attorney or compliance office, specific to the impact on their ATM installations and operation.
Architectural and Transportation Barriers Compliance Board (ATBCB) www.access-board.gov Toll-Free ADA Information Line
Call to obtain answers to general and technical questions about the ADA and to order technical assistance materials: 800-514-0301 (voice)
Department of Justice www.usdoj.gov/crt/ada enforcement updates compliance checklist
American Banker’s Association Nessa Feddis, Senior Counsel