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1. Canon U.S.A. Aubrey Woolley
Canon USA, Inc.
Government Marketing Division
2. Canon U.S.A.
3. Canon U.S.A. New Format Benefits Proposed New Format Benefit- Simpler
For some hardware devices that no longer fit into product categories (Telecom, Video and Multi-media, Self-contained, Desktop and Portable Computers)
Especially for convergent products that have outgrown categories
Unintended complication for TEITAC
Unclear which product aspects should be evaluated for some provisions. Hardware, firmware, application software, etc?
Inconsistent throughout criteria
4. Canon U.S.A. Product Example Multifunction Device (MFD)
Traditionally standalone
copiers (1194.25)
Combine functionality
of traditional copiers, printers, scanners, fax, e-mail, web access, color and b/w
- New features require additions to hardware, engine, firmware, software and web applications, dedicated PCs, etc.
5. Canon U.S.A. Buy Accessible Wizard
6. Canon U.S.A. Buy Accessible Wizard Applicability Determination Section 508 Applicability Data Type of E&IT required:
Is it a software application or operating system, or does the E&IT
include bundled software? No
Is it a web-based application or a website? No
Is it a video or multimedia production or will it include one? No
Is it a desktop or portable computer, including workstations and handhelds? No
Is it a replacement component or add-on hardware device for existing E&IT? No
Will it include analog TV or DTV receiver/tuner circuitry? No
Does it include a telecommunication function that transmits or conducts information, including voice or text? No
Will it be used standalone and NOT allow other software and/or devices to be installed or connected? Yes
Characteristics of E&IT required:
Will it have a display screen or monitor? Yes
Will it have biometric input? No
Will it provide auditory output? No
Will it have a touch screen or touch operated controls? Yes
Will it be freestanding, non-portable, intended for use in one location, and have operable controls that require physical contact? Yes
7. Canon U.S.A. Wizard Determination Results Applicable Section 508 Requirements:
1194.25 Self-contained Closed Products
1194.23 (k)1-4
1194.31 Functional Performance Criteria
1194.41 Information, Documentation, and Support
Not Applicable:
1194.21 Software Applications and Operating Systems
1194.22 Web-based Internet Information and Applications
1194.23 Telecommunications Products
1194.24 Video and Multi-media Products
1194.26 Desktop and Portable Computers
8. Canon U.S.A. Product Mapping Findings Increase in applicable criteria
23 Provisions apply to MFDs under current structure
Approximately 107 to consider under new format
Unclear to what level to test for some criteria
Hardware, firmware, software applications, web, etc.
Inconsistent as to which product aspects to test throughout format.
Comment from mapping: (3 Software & General)
Some of the provisions correspond to 1194.21, 1194.25 or both. Do these provisions cover both hardware and software? Or. should assess software for those based on 1194.21, assess hardware for 1194.25 based provisions, and both related to both? It would be much easier if the hardware and software provisions were fully separated or combined. Inconsistent as to which product aspects to test throughout format.
Comment from mapping: (3 Software & General)
Some of the provisions correspond to 1194.21, 1194.25 or both. Do these provisions cover both hardware and software? Or. should assess software for those based on 1194.21, assess hardware for 1194.25 based provisions, and both related to both? It would be much easier if the hardware and software provisions were fully separated or combined.
9. Canon U.S.A. Questions from Findings Given these complications, how do we create meaningful documentation for federal and state agencies? What information is necessary? How much is too much?
Can a clearer if/then structure be created? Or guidance about provision applicability for specific products?
How can we make this process even simpler?
EMS docEMS doc
10. Canon U.S.A. Thank you Aubrey Woolley
Canon U.S.A., Inc.
awoolley@cusa.canon.com