FAQ - Factsheet

ADA Checkout.

Just as a business has ADA parking, aisles, and restrooms, etc. Businesses are required to have an ADA checkout. It is a federal ADA law and regulation. Most businesses have been told a myth that ADA reach/range only makes a checkout ADA-compliant. 

Typical ordinary POS stands/mounts are not ADA anything, they hold a POS device in a fixed position and in no way are made to attempt to be assistive with accessibility use. This gets businesses into problematic and legal issues with the ADA and customers with accessibility needs. This is where POS Dismount D2P comes in as the assistive-accessibility POS reader mounting solution for independent accessibility use with card and PIN readers.

A lever or button, knob or slide/pull-down, arm-extender etc, mounting do not work in terms of ADA or PCI accessibility for POS card and PIN readers, if they did, we would have already utilized them as additional models or features.

ADA compliant.

The ADA is a federal law with DOJ enforcement and has accessible and accessibility requirements. States, counties, and cities also have to follow the ADA as well, -so it is not big government picking on anyone. The ADA exists with regulatory guidance to make sure everybody can accessibly use businesses and services. If you personally do not need assistive tech, consider yourself lucky. But there are many who do. 

All too often, businesses believe they are “ADA compliant” at their checkouts. We have yet to locate even one when it comes to the POS card and PIN reader with the exception of those businesses who have dismount D2P.  There is no blanket “ADA compliant”, it requires a few different things from regulation requirements. ADA guidance and components together use (the 3-ADA-A’s) ADA accessibly assistive for accessibility. 

The Two ADA O's.

Accessibility. – Assistive technology use the two O‘s in the ADA. ADA 309 Operable parts and ADA 309.4 Operations. The 309 operable parts have hardware requirements and the 309.4 has physicality requirements. 

POS Dismount uses ADA 309 operable part U-shape pull-tug (handle) that activates release for easy dismount-detach. The handle also allows for ADA 309.4 operations of no pinching, no tight grasping, no twisting of the wrist. The detach/release pull handle has less than 5 LBf pull requirement too. 

Dismount D2P (device to person) allows for the holding to transact with clarity and privacy for PIN entry.  Dismount-Transact-Re-Mount.  PCI also requires privacy using the body to PIN entry shield. This is also for cardholders who use wheelchairs. 

Physical Circumstances.

All cardholders have varied physical circumstances. Two of the major occurrences with checkouts that cardholders with disabilities have are ADA 302.8 Limited reach and strength and ADA Visual accommodation needs. ADA operable parts and operations are regulation requisite for accessibility and assistive mounting comes into demand for POS checkouts and very specifically so.  

Think in terms of spinal, shoulder rotator, distal radius, dexterity as examples etc.  

The ADA addressed the above requirements decades ago. POS Dismount D2P is the only ADA and PCI by-the-book assistive tech stands and mounts in the required way for assistive and accessibility at POS checkouts. 

Assistive REQ's in PCI.

PCI requirement: “Designed so that the cardholder can shield it (POS card and PIN reader) with the body to protect against observation of the PIN during PIN entry”. 

Devices deployed that do not use the privacy-shield requirements evaluated by the test laboratory are no longer considered approved devices.

This must be disclosed in the security policy for the device. [PCI PTS POI Evaluation FAQs – Technical]

What PCI PTS-POI requires in a matter of words is ADA assistive tech mounting for accessibility and privacy and has adopted part of the language from ISO 9564. This is for cardholder privacy use with debit PIN entry. Contrary to what most think, PIN entry debit is used more than the typical credit card in the United States.  This also covers food assistance cards which have PIN entry requirements for use too. 

ADA Reach/Range.

Reach range standards take into account the diverse range of abilities and disabilities. They are essential to elements, such as grab bars, door handles, and other controls, can generally be reached and used by people with varying physical capabilities as examples.  The POS checkout is far different. 

Dismount D2P is to be placed within the ADA reach/range. The assistive technology design and purpose provide independent and assistive-accessibility use for the cardholder with varied diverse mounting situations, varying physical capabilities and limited reach and strength, POS screen view, PIN entry privacy, etc. 

A better understanding.

One area that has continued to provide obstacles for persons with disabilities, particularly persons confined to wheelchair, is interfacing with mounted interface devices, for example, credit card terminals at check-out lanes in retail stores. The terminals are often mounted on check-out counters, and positioned at a height that is convenient for most consumers who are standing at the counters. 

For persons in wheelchairs, however, who are typically seated in their chairs, and positioned considerably lower than standing customers, the height of the terminals poses considerable difficulties. 

It is sometimes sadly necessary for others to insert the disabled person’s credit card, or to enter private PIN numbers into a terminal. Oftentimes, the only practical way for a person confined to a wheelchair to enter private PIN numbers is for the confined person to reveal the private code to another person, who physically enters the numbers into the terminal interface.

Rather than positioning the payment devices at levels optimal for persons confined to wheel chairs, most stores have elected to position the devices at height levels that are convenient to persons who are physically able to stand at the check-out counters, the number of which greatly exceeds the number of wheelchair-bound customers. 

As a result, persons confined to wheelchairs have been forced to suffer the inconvenience and security risks of interacting, either directly or with the need for assistance of another person, with non-accommodating payment devices.

Federal Requirements.

How many? One ADA POS checkout minimum. If more than four sales/service counters, one for every four is to be the open checkout at all times of store operating hours. If multi-lane, one per four checkout lanes. example: Lane 1, Lane 5, Lane 9, etc. 

Legal problems around ADA access and PCI cardholder security are a touchy subject and nobody likes to talk about them, however, it is a very real thing, and is why cardholder ADA or PCI should not be ignored, especially at checkouts where people’s financial cards and personal PIN numbers can be exposed and breached. 

Enforcement Action: (ongoing). What constitutes a violation of the ADA?
It violates the ADA to fail to provide reasonable accommodation to the known physical limitations of a qualified individual with a disability.
 
Federal law fines of up to $75,000 for the first violation and $150,000 for additional ADA violators. Additionally, – The State of California has additional fines of $4,000 to $6,000 via CAL-FIN 13082. Additionally, attorney costs and legal fines come into play. It happens daily.  PCI penalties vary from $5,000 to $100,000 per month until the merchants achieve compliance.
PCI and VISA REQ's.

(Partial)

PCI PTS POI Compliance: (accessibility requirement).

The PED must provide a means to deter the visual observation of PIN values as they are being entered by the cardholder.

The cardholder needs to shield the card and PIN reader with the body to protect against observation of the PIN during PIN entry. (think wheelchair or a little person, limited reach and strength, visual screen accommodation as a few examples). 

Commonly seen POS mounting in businesses cannot address the accessibility requirements of ADA, PCI, ISO or the inclusion ethics of DEI(A). 

Google states it in a really good way concerning it all: “Product inclusion and equity is the ongoing work of building belonging through our products, by centering the most marginalized voices at every phase of product creation”.

The product creation of POS Dismount D2P product inclusion is specifically engineered to address these requirements and concerns for cardholder use and compliances, including apparent or non-apparent levels of ability that limit a person’s POS checkout activities.

Visa Core Rules Section 1.1.1.3 Compliance with Laws and Regulations.

Each Member is also responsible for ensuring that any of its affiliates, subsidiaries, parent companies, third-party agents, Merchants, and any other of its appointed agents participating in Visa’s system comply with all applicable laws, regulations, and other legal requirements applicable to each country in which its affiliates, subsidiaries, parent companies, third-party agents, Merchants, and other appointed agents operate.
(ADA is a Federal Law with regulations).

Visa TADG 3.2 – 2.6 Accessibility Requirements Device vendors and acquirers are responsible for ensuring that all customer-facing devices adhere to any and all accessibility requirements for the countries in which they operate and for the countries in which the devices are installed. (Again, -ADA is a Federal Law with regulations). If your business accepts VISA, TADG 3.2 2.6 also applies. 

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