Disability customer equipment

Background

Labelling requirements for customer equipment (CE) are specified in the Telecommunications Labelling (Customer Equipment and Customer Cabling) Notice 2001 (Telecommunications Labelling Notice). The compliance arrangements in the Telecommunications Labelling Notice require manufacturers and importers (suppliers) to ensure that their CE meets specified technical standards and is labelled to indicate compliance with those standards. Suppliers are also required to maintain documentary evidence of compliance (compliance records). Compliance levels range from compliance level 1, which is the lowest, to compliance level 3, which is the highest.

A compliance scheme has been introduced to reduce compliance arrangements for specific CE, identified as disability customer equipment.  The aim of the reduced compliance requirements is to minimise the compliance costs for CE which has one or more features designed to assist persons with disabilities access services supplied over the analog public switched telephone network where the CE is supplied in low quantities (not more than 50 items from each supplier in a calendar year).

To function effectively the scheme requires the cooperation of suppliers and disability representative bodies.

Fundamental to the operation of the scheme is the endorsement by a disability representative body that the equipment to be supplied under this arrangement does have a feature or features that, in the opinion of that body, are specifically designed to assist a person with a disability to access a service supplied over the analog public switched telephone network.

In addition, the feature or features that meet the special needs of persons with disabilities cannot be a feature which is addressed by ACIF Standard AS/ACIF S040 (S040). The standard S040 specifies features catering for persons with a disability that must appear on all CE used in accessing the Standard Telephone Service. (Currently the two features covered by S040 are a raised pip key on the key associated with the digit '5' and the incorporation of hearing aid coupling into the handset.) While S040 currently contains these two features only, the standard is currently being reviewed.

Compliance requirements

In brief the Telecommunications Labelling Notice requires suppliers to:

• identify the feature or features of the equipment specifically designed to cater for the needs of persons with disabilities. If the equipment has more than one feature that would make it suitable to be disability customer equipment, each of the features must be listed on the Declaration of Conformity-disability customer equipment;
• obtain a written statement from a disability representative body that the feature or features will assist a person with a disability to access a service supplied over the analog public switched telephone network. A supplier may use the Declaration of Conformity to seek endorsement of the disability representative body or may submit a form containing, as a minimum, the information specified in the Declaration of Conformity.
• supply not more than 50 items of disability customer equipment in a calendar year;
• test the disability customer equipment to the reduced compliance arrangements specified in category A51 of Schedule 1 of the Telecommunications Labelling Notice. Compliance level 3 (testing by a recognised testing authority) still remains for electrical safety requirements.
• hold the original Declaration of Conformity in their compliance records for the disability customer equipment and send a copy of the signed Declaration of Conformity to:
  
  Patrick Emery
  Manager
  Technical Regulation Development Section
  Australian Communications and Media Authority
  PO Box 13112 Law Courts
  Melbourne Vic 8010
  Fax: (03) 9963 6899
  Email: comply.label@acma.gov.au

• label the equipment with the A-Tick regulatory compliance mark.

Disability customer equipment

Disability customer equipment means customer equipment that:

• is for use by persons with disabilities;
• has a feature or features:
  • designed with the purpose of assisting a person with a disability to access a service supplied over the analog public switched telephone network; and
  • that is not one of the features specified in S040;
• has been identified by a disability representative body as having a feature that will assist a person with a disability to access a service supplied over the analog public switched telephone network;
• is not supplied in quantities greater than 50 items in a calendar year (where more than 50 items of a specific disability customer equipment is supplied in a calendar year it will no longer be eligible for the reduced compliance arrangements); and
• can only connect to the analog public switched telephone network (that is to say that this equipment would, if it were not classified as disability customer equipment, be scoped by Category A1 or A2 to Schedule 1 of the Telecommunications Labelling Notice).

Disability representative body

A Disability Representative Body, for the purpose of this arrangement, means a body that:

• represents a group of persons with a disability;
• is funded by the department responsible for family and community services; and
• is listed on the ACMA website as a disability representative body.

Role of the disability representative body in assessing disability customer equipment

The disability representative body must provide the ACMA with the identity and contact details for a signatory who is authorised by that body to endorse equipment as disability customer equipment. In order for the scheme to be effective, the disability representative body must ensure that name and contact details stored on the ACMA website are updated as required.

The disability representative body will be asked by the supplier to assess that the equipment has a feature or features that would assist a person with a disability to access a service supplied over the analog public switched telephone network. The equipment may have many such features, the disability representative body is only required to identify one of the features in order for the equipment to be disability customer equipment (the supplier is required to list on the Declaration of Conformity all of the features that would make it disability customer equipment).

The supplier may present the Declaration of Conformity for endorsement by the disability representative body; the Telecommunications Labelling Notice allows suppliers to submit any form which contains, as a minimum, the information in the Declaration of Conformity.

There is little limitation to the type of feature that may be considered as being suitable for disability customer equipment; features which are listed in the standard S040 are not suitable for categorising an item of CE as disability customer equipment. Features which may be considered as suitable by a disability representative body include, but are not limited to, larger buttons, non-slip buttons, larger display screens and voice recognition incorporated into equipment.

In assessing whether an item of CE presented by a supplier is disability customer equipment, the disability representative body should be satisfied that the feature, in conjunction with the equipment in which that feature is incorporated, would assist a person with a disability to access a service supplied over the analog public switched telephone network.

Notes for suppliers

The supplier is bound by the requirements of the Telecommunications Labelling Notice.

Suppliers should consider early in the process whether the equipment they are manufacturing, importing or modifying will be recognised as disability customer equipment by a disability representative body. Equipment that is not acceptable to a disability representative body is not eligible for the reduced compliance arrangements and must meet all the applicable standards specified in the appropriate categories of Schedule 1 to the Telecommunications Labelling Notice. The ACMA will not act as an arbitrator to this process; issues on the identification of disability customer equipment must be addressed with the disability representative body.

Equipment which is scoped by any Part A Category, other than A1 or A2, of Schedule 1 to the Telecommunications Labelling Notice cannot be disability customer equipment.

The supplier must complete a Declaration of Conformity and must return a copy of the completed declaration to the ACMA.

Disability representative bodies participating in the compliance scheme