Comment from Lewis, Clayton

Document ID: ATBCB-2011-0007-0027
Document Type: Public Submission
Agency: Architectural And Transportation Barriers Compliance Board
Received Date: February 27 2012, at 12:00 AM Eastern Standard Time
Date Posted: March 7 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: December 8 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: March 7 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80fc4589
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More protection is needed for workers with cognitive disabilities. (1) People who cannot read for cognitive reasons should be supported. A provision of the following form would be appropriate: 302.X Without Reading. ICT shall provide at least one mode of operation that does not require users to read text. (This mode might perhaps not be different from those provided for users who cannot see, but the provision nevertheless serves to recognize the existence of a class of users not now recognized in the list of functional performance criteria.) (2) Technology should not impose cognitive demands beyond those involved in the work being performed. Without a provision addressing this requirement, a worker performing well could lose his or her job when technology was introduced that imposed new cognitive demands. A provision of the following form would be appropriate: 302.X Minimize Added Cognitive Demands. ICT shall provide at least one mode of operation that minimizes cognitive demands, beyond those of the tasks the ICT supports, imposed by the ICT itself.

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