ADA + ICT + PCI Rules.

[Public retail, includes (all) State, County, City]: 

Dismount D2P is an ADA + PCI card and PIN mounting device providing cardholders with an assistive interactive technology (AT) user experience at the POS checkout. Dismount D2P uses ADA operable part U-shape Pull with an easy-to-use detach/attach assistive technology feature that supports additional ADA requirements for an accessible card and /or PIN reader mounted checkout use.

Designed so that the cardholder can shield it with the body to protect against observation of the PIN during PIN entry. (How to do this from a wheelchair?). Dismount D2P. 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. POS Dismount is the fix. [PCI PTS POI Evaluation FAQs – Technical]

The ADA addresses readily achievable standards for access and in the case of the POS card and PIN reader, -hard-mounted POS devices are not considered accessible.  See the example picture and video below.

PCI also has hard compliance requirements in its PTS-POI for accessibility as well as the Card Brands such as accepting Visa Card as an example.

[Federal and Military] 

https://www.irs.gov/irm/part2/irm_02-030-001

Legislation, federal guidance and Treasury directives require that federal agencies make their ICT accessible to people with disabilities. These laws and directives include:

Section 508 of the Rehabilitation Act of 1973 amended in 1998 (29 U.S.C. §794(d) Electronic and Information Technology) and refreshed by the U.S. Access Board via final rule in the Federal Register (82 FR 5790) effective March 23, 2018, requires federal agencies to develop, procure, maintain and use ICT that is equally accessible and usable to persons with disabilities unless a Section 508 exception is established.

Business Liability Problems.

POS Reader Checkout Obstacles.
Play Video
Checkout Problems.

The person in the above video happened to be in front of some of our team in a grocery store in California, we had no idea this person had a prosthetic use at the time either. We see this type of situation a lot, but this one stands out to show reach and range problems as this counter is generally considered (high) but is flat-horizontal directly with this card holder. We often point out these issues at any business checkouts.  

This is also the type of problem that gets businesses into legal trouble with accessibility requirements not being implemented. It is all too common and is exactly why the ADA has standards in place.  We will point these out below along with the standards used with POS Dismount. The definitions and use are what separate POS Dismount from all other POS Mounting.  Another big deal for checkouts is customer latency some are high few are low it in, Dismount speeds the process by lowering it. 

POS Dismount is:

Assistive Technology (AT) and (Independent accessibility requirements).
Any item, piece of equipment, or product system, whether acquired commercially, modified, or customized, that is used to increase, maintain, or improve functional capabilities of individuals with disabilities.

Dismount is for businesses and for POS service and equipment providers ready to provide ADA-inclusive checkouts to their customers.

Access to Functionality

Information and Communication Technology (ICT)
Information technology and other equipment, systems, technologies, or processes, for which the principal function is the creation, manipulation, storage, display, receipt, or transmission of electronic data and information, as well as any associated content. Examples of ICT include, but are not limited to: computers and peripheral equipment; information kiosks and transaction machines, (SSTM’s); telecommunications equipment; customer premises equipment; multifunction office machines; software; applications; Web sites; videos; and, electronic documents.

Public Facing.

Public Facing
Electronic content that is public facing shall conform to the accessibility requirements. Closed Functionality Characteristics that limit functionality or prevent a user from attaching or installing assistive technology.

Terminal Device or software with which the end user directly interacts and that provides the user interface. For some systems, the software that provides the user interface.

When a manufacturer determines that conformance to one or more requirements in Chapter 4 (Hardware) or Chapter 5 (Software) would not be readily achievable, it shall ensure that the equipment or software is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to the extent readily achievable.

302.2 With Limited Vision: Where a visual mode of operation is provided, ICT shall provide at least one mode of operation that enables users to make use of limited vision.

302.8 With Limited Reach and Strength: Where a manual mode of operation is provided, ICT shall provide at least one mode of operation that is operable with limited reach and limited strength.

Limited Manipulation

Where a manual mode of operation is provided, ICT shall provide at least one mode of operation that does not require fine motor control or simultaneous manual operations.

ICT with closed functionality shall be operable without requiring the user to attach or install assistive technology other than personal headsets or other audio couplers, and shall conform to 402. POS dismount assistive mounting uses (detach) by operable part u-shape pull and operation requirements to gain access to hard-mounted and laydown terminals to (attach) too if needed. It allocates easier use for additional ICT assistive technology to attach/detach too. 

Transactional Outputs

Where transactional outputs are provided, the speech output shall audibly provide all information necessary to verify a transaction.

Speech output for any single function shall be automatically interrupted when a transaction is selected. Speech output shall be capable of being repeated and paused.

Where provided, operable parts used in the normal operation of ICT shall conform to 407.

Tactilely Discernible

Input controls shall be operable by touch and tactilely discernible without activation.  – Again, this is exactly where limited reach and strength come into problems whether mounted high or low and is exactly why the operable parts and operation with providing indepent access to attach and detach. 

In other words, if you have to have the ease of attaching, it stands to reason in the requirements that it must too be detachable. 

True reach/range.

Whether a POS terminal is the typical fixed mounted high or low, it does not address regulatory requirements or that of PCI PTS POI or the card brand’s requirements for accessibility. 

ADA Reach/Range is only measurement. Accessible design is a design process in which the needs of people with disabilities are specifically considered. 

PCI specifically states in it PTS POI that a person must be able to PIN sheid using their body. This is completely impossible with fix mounted and laydown POS card and PIN readers. This also is in conditions for attaching and detaching other assistive uses as explained above. 

As it stands, we have yet to experience any actual compliant assistive mounted card and PIN readers except the businesses that use our POS dismount (D2P). 

D2P means device-to-person which allows a cardholder the ease of use and interaction which is under the accessibility requirements and protection of the ADA and 508 (ICT) whether a public or governmental facility. 

A person can interact safely in comfort with the card reader using dismount and hold the device as a person sees fit to use for a card transaction and especially a PIN debit transaction. Dismount is accessible, affordable and readily achievable.

ADA 309 + 309.4

Operable parts and Operations. The four major factors in using a POS device for accessibility. We use the U-Shape Pull handle found in ADA 309 operable parts and the 309.4 operations which requirements are no pinching, twisting of the wrist, tight grasping and release pull in under 5lbs. Add this with the 302.8 limited reach and ADA visual accommodation, it is the perfect ADA solution which too satisfies the PCI-PTS-POI PIN shielding privacy requirements. Inclusion does matter. 

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