Accessibility DOT/CTA Updates
New Air Carrier Access Act Regulations New rules were published December 12, 2013 as part of DOT s continuing implementation of the Air Carrier Access Act. Website accessibility US and Foreign carriers Not Airports Effective December 12, 2015, US and foreign carriers that operate at least 1 aircraft having a seating capacity of more than 60 passengers, and own or control a primary Web site that markets air transportation to consumers in the US must (1) ensure 7 core functions on their public facing pages on their primary website meet WCAG 2.0 Level A and AA web accessibility standards (2) consult disability organizations on the usability of the 7 core functions, and (3) provide a mechanism on your primary Web site for persons with disabilities to request disability accommodation services for future flights.
Kiosk Accessibility US and foreign air carriers that own, lease, or control automated airport kiosks at US airports with 10,000 or more annual enplanements are required to ensure that 25% of automated airport kiosks installed 3 or more years after the rule s effective date meet the required technical accessibility standards. By December 12, 2022 at least 25% of automated kiosks in each location at an airport must be accessible. Carriers and airports are jointly liable for shared use kiosks.
Key dates to note for US airport kiosks: - Effective December 12, 2016 25% of installed automated airport kiosks are required to meet the technical accessibility standards. - Effective December 12, 2022 at least 25% of automated kiosks in each location at an airport must be accessible. Automated airport kiosk provides carrier software applications that enable customers to independently access flight related services. Shared-use automated airport kiosk - a self-service transaction machine that is jointly owned, controlled or leased by an airport operator and carriers and/or an independent service provider and that provides carrier software applications which enable customers to independently access flight-related services.
Between 2016 and 2022: Installed is the key take away o Nothing changes until kiosks are installed. o The regulation applies only to the cluster of kiosks that are being installed. Example: Carrier/airport is adding a cluster of 100 kiosks to an already existing cluster of 100 kiosks; only 25% must be accessible. o When the existing cluster of 100 kiosks are replaced (installed) 25% must be accessible. o If the carrier wants to voluntarily get ahead of the game, knowing they will have a total of 200 kiosks in the future, the carrier could choose to install 50 accessible kiosks but they are required to install only 25 accessible kiosks at the time 100 additional kiosks are added.
Highlights: - Accessible automated kiosks in each location at an airport must provide all of the same functions as inaccessible kiosks in that location - Must ensure that accessible automated airport kiosks are visually and tactilely identifiable and maintained in working condition - The standard applies when kiosks are installed not just new kiosks - 25% applied on a per location basis, installing 12 kiosks, 3 must be accessible - Airports and carriers are jointly and severally liable for ensuring that shared-use automated airport kiosks meet accessibility requirements
Industry Compliance Plan is under development to address all requirements, some solutions include: - Visual/Tactile identification of kiosks - Universal blue wheelchair accessibility symbol is placed on the accessible kiosks - first position kiosk is accessible, signage advising passengers with a disability have priority access - Agents should monitor and manage usage of accessible kiosks - Timing (of operable parts). Where a timed response is required, the user must be alerted visually and by touch or by sound and given an opportunity to indicate more time is required. - Industry standard includes the alert - The platform must adjust the total session timeout to 30 minutes as soon as the application performs the notify (ACTIVE_ACCESSIBLE) request - Plugging in/out the headset triggers/disconnects accessibility mode
Cluster Gray area No formal government definition of a cluster case by case basis Discussions with DOT have clarified criteria that distinguishes clusters are: *proprietary kiosks *common use kiosks *functionality of kiosks *groupings of kiosks Example: Proprietary kiosks with self tagging functions would be one cluster Document your analysis of what constitutes a cluster and retain for DOT audits.
- Status indicators (for operable parts) must be discernable visually, by touch or by sound - Navigation pad such as easy access could be installed - Traditionally 4 types of status indicators have also been used - Dedicated such as easy access - Full data keyboard if used must be Qwerty with tactilely discernible F and J keys (standard on most keyboards today) - ATM selection keys - 12 or 16-digit number entry pad - Traditionally 5 defined action keys are used - Up/down - Action - Help - Forward/back - Enter
Clarifications pending: - List of everything considered in scope in the kiosk universe - APC kiosks (CBP, DOT and A4A are working towards clarification whether they are included) - Tickets and Boarding Passes - Orientation must be tactilely discernible if orientation is important to further use of the ticket or boarding pass - Industry solution is to audibly describe the document - Small working group has developed sample language to audibly describe the boarding pass orientation - Open Doors to review - Goal is to convince DOT that audible description is better than tactile - If DOT does not agree, industry will have to file an equivalent alternative application with DOT
Confirmation from DOT: - Characters displayed on the screen must be sans serif font, 3/16 inch high minimum and background contrast must be a minimum luminosity contrast ratio of 3:1, sans serif is not one font but a style - Biometrics if biometrics is the only means for user identification, 2 biometric options using different biological characteristics must be provided - Size the clear floor or ground space shall be at least 30 inches by 48 inches - Use of headset as an industry standard - In scope are kiosks with additional functions, including, but not limited to bag drop, flight recovery, bag recovery and customer service
Coordination with External Resources for Expertise - Open Doors - Met with the Accessibility Kiosk Working Group in Chicago in May 5-6 - Supported the solutions agreed upon by the industry - Will assist in development of the audio instructions for orientation of a boarding pass - CUSSMG - Version 1.4, which addresses kiosk accessibility, was published March 31, 2015
Canadian Transportation Agency (CTA) Accessibility Rule Published December 17, 2014 Therefore, transportation service providers subject to this Code can install automated self-service kiosks that meet the standards of either section 1.3 of this Code (and the accompanying implementation guide) or 14 CFR Part 382 (Nondiscrimination on the Basis of Disability in Air Travel), 382.57 (What accessibility requirements apply to automated airport kiosks?) and 49 CFR Part 27 (Nondiscrimination on the Basis of Disability in Programs or Activities Receiving Federal Financial Assistance), 27.71 (Airport facilities), as it pertains to automated kiosks at U.S. airports. Carriers and terminal operators should ensure that at least 25 percent of automated self-service kiosks located in each service area of an airport, rail or ferry terminal meet the standards in section 1.3 and the accompanying implementation guide by December 31, 2022. Carriers and terminal operators should ensure that all automated self-service kiosks installed on or after December 31, 2016, meet the design and functional specifications set forth in section 1.3 of this Code and the accompanying implementation guide, until at least 25 percent of kiosks provided in each service area of an airport, rail or ferry terminal meet this specification.
Canadian Transportation Agency (CTA) Accessibility Rule Published December 17, 2014 Applies to: Air Terminal Operators: Operators of terminals within the National Airports System. Air Carriers: Canadian (As defined in the Canada Transportation Act, i.e. "Canadian" means a Canadian citizen or permanent resident within the meaning of the Immigration Act, a government in Canada or an agent of such a government or a corporation or other entity that is incorporated or formed under the laws of Canada or a province that is controlled in fact by Canadians and of which at least seventy-five per cent, or such lesser percentage as the Governor-in-Council may by regulation specify, of the voting interests are owned and controlled by Canadians.) air carriers that operate fixed-wing aircraft with 30 or more passenger seats used for providing passenger service.
CTA Accessibility Rule Published December 17, 2014 The DOT rule is available on the Internet at: www.regulations.gov, docket DOT-OST-2011-0177. The CTA rule is available on the internet at: https://www.otc-cta.gc.ca/eng/removing-communicationbarriers
Questions: Email pedwards@airlines.org Thank you!