Mike Martin, John Gjöderum, Erkki Kemppainen
Developments in the fields of telematics and telecommunications have made possible a means of communication for people with disabilities that are very wide ranging and can effect their lives in a most beneficial manner if they are developed with the needs of this substantial sector of the community in mind. These new developments however also bring with them problems that can prevent people from using them. A further requirement for standardization, which takes into account the needs of elderly and disabled people, is to prevent the negative effects that come about due to the break-up of state controlled monopolies and the liberali-zation of telephone equipment supply. Appropriate standards should ensure that in the design and provision of telecommunications services and equip-ment the requirements to meet the needs of disabled and elderly people will be unambiguously stated and vigourously implemented. Given the principles of standardization that are set out below it can be seen that standardization offers an opportunity for minimizing problems before they occur.
The development of standards clearly requires that the needs of the users are a primary consideration and therefore their involvement is also of prime importance. However for elderly and disabled people this presents problems due to the way in which standards are produced and the technical nature of the subject matter in telecommunications. Attempts are being made to overcome these problems and to bring about an awareness of the needs of disabled and elderly people in the production of standards. The HEART project is one attempt by the TIDE programme to address this problem (TIDE-HEART, 1995). A major difficulty, described below, is the vast scope of standardization even in one field such as telecommunications.
Aims of Standardization
The aims of standardization should be made clear in order to avoid confusion but in general do not appear to have been specifically stated. However, as an example, these aims have been stated in British Standard BS 0: Part 1: 1991 A standard for standards. Part 1. Guide to general principles of standardization, as follows:
a) to promote the quality of products, processes and services by defining those features and characteristics that govern their ability to satisfy given needs i.e. their fitness for purpose;
b) to promote improvements in the quality of life, safety, health and protection of the environment;
c) to promote the economic use of materials, energy, and human resources in the production and exchange of goods;
d) to promote clear and unambiguous communication between all interested parties, in a form suitable for reference or quotation in legally binding documents;
e) to promote international trade by the removal of barriers caused by differences in national practices;
f) to promote industrial efficiency through variety control.
The above aims very clearly imply that for telecom-munications and the needs of disabled and elderly people there is an overall aim to provide society-wide communication.
Principles of Standardization
Standardization is seen in different ways by different people depending on their position and their aims and objectives in bringing about standardization. It is there-fore of some importance to state the main principles of standardization which are relevant to telecommunications:
a) standards should be wanted;
b) standards should be used;
c) standards should be impartial;
d) standards should be planned;
e) standards should not be duplicated.
These principles can then be discussed in terms of their relevance to disabled and elderly people.
a) Standards should be wanted
This implies that all parties concerned want the same standards, which is not always true, and are willing to reach a voluntary agreement to achieve a stated purpose. This in turn implies that there is a consensus that it is possible to reach agreement, which is not always the case. An example of this is the protracted battle that has taken place over the question of standardizing the communication protocols for text telephones. Commercial and nationalistic attitudes have maintained outdated protocols in place in spite of a great need for standardization. However consensus has taken place (see Section on Activities in European standardization p.76) largely due to work by experts in the field of telecommunications who have no direct involvement in the field of disability but who sought to solve a technical problem.
b) Standards should be used
The publication of a standard is of little value if it is not used. It is therefore important that the intended application of the standard is clearly understood when work is started on it. The cost of producing standards is very high and they take at least two years to produce as they involve groups of experts who will need to come from a significant number of countries. Draft standards then have to be circulated to all countries for comment, the comments dealt with to the satisfaction of enough countries to obtain a positive vote in the final stage.
However a number of standards are produced which are thought by groups of experts to be relevant but in practice are of little value to manufacturers or consumers, while other standards are not produced because of the lack of support and yet are needed by consumers. This raises the question of the involvement of disabled consumers, which is easy in principle to resolve but difficult in practice due to the high cost involved, which is borne by the individuals involved in the work, and the level of technical expertise required to write standards.
c) Standards should be impartial
Standards should be produced that benefit the whole community and not give an advantage to any one supplier of goods or services.
d) Standards should be planned
The social and/or economic benefits of a standard should be compared with the cost of producing and implementing it. Standards can only be written if there is a basis for agreement on a national or even more today an international basis. Due to the high cost of producing a standard, care has to be taken to select clearly defined subjects that are sufficiently stable in their technological development or their principle of operation to make it possible to write a standard that will be useful for at least five years, at which time it should be reviewed.
e) Standards should not be duplicated
Standards can be produced at different levels: by individuals, firms, associations, countries, regions and world-wide. For economy of effort, they should be produced for the largest group that has a need for the standard in an agreed time scale. However, before starting work on a standard, it should be established that no standard exists or that the subject matter is not covered in a number of different but not necessarily related standards which is often the case for aids for disabled people.
What Organizations are Involved in Standardization
To those people who are not involved in the standards field it may appear to be a relatively simple matter to interact with the organizations that are involved in standards work. However, in practice it is difficult to know which is likely to be the main organization involved, and even more difficult to determine the interactions between organizations when it comes to standards that are relevant to disabled and elderly people.
To illustrate the size of the work, the two main inter-national standards organizations are the International Organization for Standardization (ISO) and the International Electrotechnical Organization (IEC). ISO involves the national standards bodies of 75 countries, has over 160 technical committees, 650 subcommittees and 1500 working groups, and has produced over 6000 standards. IEC comprises the national electrotechnical committees of over 40 countries, has over 75 technical committees and 115 subcommittees, which have produced over 1500 standards.
In Europe the two main standardizing organizations are CEN (Comité Européen de Normalisation) and CENELEC (Comité Européen de Normalisation Electrotechnique), with a special responsibility for telecommunications being given to ETSI (European Telecommunications Standards Institute). It should be noted that over 90% of CEN and CENELEC standards are either an adoption of IEC or ISO standards or they form the basis of the European standard. The reason for needing European standards is that IEC and ISO standards are not mandatory and therefore there is a need to produce European Norms (EN) standards that can be used with European legislation.
Therefore, to be able to keep up with all aspects of standardization, even in one area is a major task. The above are major international or European organizations but in addition to these there are numerous national and trade organizations that are highly relevant to the needs of disabled people. Any of these organizations may produce standards that eventually are called up by legislators for enforcement purposes.
Organization - Committee - Areas of Interest
IEC TC 29 - Electroacoustics - Hearing aids
IEC TC 77 - Electromagnetic Compatibility - All equipment
IEC TC 60 - Safety of Electrical Equipment - All equipment
ISO TC 173 - Aids for the Handicapped - All equipment
CEN TC 293 - Aids for the Handicapped - All equipment
CENELEC TC 62 - Safety of Electro Medical Equipment - All equipment
ETSI HF 2 - Human Factors - All telecom equipment
ETSI TE-4 - Voice Terminals - Coupling of hearing aids to telephones
ITU-T - Study Group 12 - Text telephones
ITU-T - Study Group 14 - Inductive coupling
(Table 3-1) The following table lists as an example of the problem those organizations and committees that have a specific relevance to one group of disabled and elderly people i.e. those who are deaf or hard of hearing.
How standards are produced
The problem for disabled and elderly people is therefore to ensure that their needs are made clear to all of these various committees. Organizations for and of disabled people should therefore ensure that they have within their organizations people or groups who are actively involved in the standards work; however, to keep track of all the possible standards that are likely to affect them is a very large task.
Because of the enormous cost of producing standards and the length of time involved, a set of formal procedures are used by IEC and ISO for the production of standards. These procedures are similar to those used in most standards organizations and cover 5 stages as follows:
Preliminary Stage - Stage 0
This is an investigative stage to determine if there is a need for the standard and if there is enough knowledge available to develop a standard.
Proposal Stage - Stage 1
If Stage 1 shows the need for work, a proposal must then be prepared which is circulated to all member countries to establish that they are in favour of the work and if they wish to participate in it. At least 4 countries have to agree to the work before it can start.
Preparatory Stage - Stage 2
Here the detailed work has to be started to produce a working draft of the standard and, depending on the complexity of the subject and the level of agreement amongst those working on the standard, this stage can take several months to several years. Time limits are now placed on this and all other stages due to the length of time that has elapsed in some cases before a first draft has been produced.
Committee Stage - Stage 3
Once a working draft has been produced, it is then submitted to the relevant committee for approval to be sent out to all countries for comment. The purpose of this stage is to attract the widest possible support and comment on the document. The working group responsible for the document will then consider the comments and if these are easily dealt with pass the document on for the next stage. However if there is substantial comment they may decide that it is necessary to send the document out for further comment.
Approval Stage - Stage 4
Once the document is thought to be in a form that will be acceptable to a majority of countries it is then sent out for a formal vote. In principle no further technical changes can be made to the document and countries have to vote for or against it or formally abstain. A straight majority with all countries having equal weight decides if the document becomes a standard.
Publication Stage - Stage 5
The final work is in editing, printing and distributing the document to all the national standards bodies.
Standards are not automatically distributed to interested parties, but have to be purchased from standardizing organizations, often at considerable cost. Information on the availability of standards is normally only available from National Standards organizations or professional bodies, which creates a problem for voluntary organizations who wish to keep themselves informed of new standards.
Types of Standard
There are three types of standard, codes of practice and technical reports. The standards can be divided into those concerned only with measuring the performance of a device e.g. IEC 118 Hearing aids, those concerned with specifying the performance requirements of a device such as a wheelchair, those concerned with specifying general requirements for a range of devices e.g. IEC 601 Safety of Electro Medical Devices and those that give requirements for quality assurance e.g. ISO 9000. In addition there are codes of practice such as those in the UK for the installation of induction loops and finally, where it is not possible to obtain agreement, there are technical reports, which make available the knowledge obtained but have no status as standards.
Should and Shall
While standards are not mandatory, there may in practice be means by which compliance with Directives, etc. is established.
The two words "should" and "shall" are crucial in standards, in fact it might be said that a standard that is not mainly comprised of "shall" is not a standard. The reason for this is that "shall" means that the requirement is mandatory and must be complied with. "Should" implies that it is not obligatory and therefore if a standard is largely comprised of "should" it really carries no weight as the person making the product can ignore the requirement.
How Can Disabled and Elderly People Be Involved ?
From the above it may be seen that there are areas of difficulty for disabled and elderly people in influencing standards. First there is the need to get in at the beginning and to see that the content of the standard meets their needs. Then there is the problem of being involved in the detailed work on the standard, which may involve a number of meetings in different places around the world or at least around Europe. There then follows the difficulty of influencing the national vote on the document, which can only come through the national standards organization. It may be that even if that is done there will be a different vote from the majority of other countries, which will confound the aims of the originators. A European study has suggested a need for consumer involvement (TIDE-HEART, 1995).
A "New Approach" to Standardization
A new approach to technical standardization in Europe was adopted by the European Council of Ministers in their Resolution of the 7 May 1985 on technical harmonization. This Resolution states that legislation will be limited to setting out essential safety and other requirements to which products put on the market must conform. Technical standards setting will be delegated to specialist organizations and remain voluntary, although compliance with a technical standard produced by such a body will provide conclusive evidence that a particular product also complies with the "Essential Requirements" contained in the relevant EC Directive. The product is then guaranteed freedom of movement throughout the European Union (Shaw, 1993).
The following fundamental principles for the new approach are set out in the resolution below:
"- Legislative harmonization is limited to the adoption by means of Directives based on Article 100 of the EEC Treaty, of the essential safety requirements (or other requirements in the general interest) with which products put on the market must conform, and which should therefore enjoy free movement throughout the Community,
- the task of drawing up the technical specifications needed for the production and placing on the market of products conforming to the essential requirements established by the Directives, whilst taking into account the current stage of technology, is entrusted to organizations competent in the standardization area,
- these technical specifications are not mandatory and maintain their status as voluntary standards,
- but at the same time national authorities are obliged to recognize that products manufactured in conformity with harmonized standards (or, provisionally, with national standards) are presumed to conform to the "Essential Requirements" established by the Directive. (This signifies that the producer has the choice of not manufacturing in conformity with the standards but that in this event he has an obligation to prove that his products conform to the Essential Requirements of the Directive)."
The general requirements for products are contained in the "Essential Requirements" part of the relevant Directives. However the detailed requirements are defined by Standards adopted by the "Competent Bodies" who are recognized in each country by the European Commission as the official guardians of the implementation of the Directives.
The Resolution of the Council of Ministers indicates the belief that standardization goes a long way towards ensuring that industrial products can be marketed freely. It also goes towards creating a standard technical environment, not only in the European Union, but also world-wide, especially in new technologies.
For example, Council Directive on the approximation of the laws of the Member States concerning telecommu-nications terminal equipment (91/263/EEC), including the mutual recognition of their conformity refers to the new approach to technical harmonization and standards. CEN, CENELEC and ETSI are the bodies recognized as competent to adopt harmonized standards. The Directive defines a "standard" as a technical specification adopted by a recognized standards body for repeated or continuous application, compliance with which is not compulsory.
The Development of Harmonized European Telecommunication Standards
This section is intended to give a brief overview of the bodies and committees involved in the harmonization process of telecommunications technical standards and their conversion into Technical Regulations. Figure 3-1 gives a diagrammatic representation of the interactions of the main bodies involved. It should be noted that these interactions do not directly involve consumer groups.
The development of Common Technical Regulations (CTRs) normally follows the procedure outlined below:
The Commission tables before the Approvals Committee for Terminal Equipment (ACTE) a proposal for the development of a CTR in a particular area.
If the opinion of ACTE is favourable the Commission will ask the Telecommunications Regulatory Applications Committee (TRAC) to draft a scope statement for the CTR.
This draft scope is then tabled in ACTE and modifications can be made.
When ACTE is agreed on the scope of the CTR the Commission asks the European Telecommunications Standards Institute (ETSI) to develop a Technical Basis for Regulation (TBR) based on the scope statement.
When complete, the TBR is tabled in ACTE for approval.
When approved, the TBR goes to the Commission who adds the regulatory aspects to it and transforms it into a CTR.
The CTR is then published in the Official Journal (OJ) and enters into European Union law.
The key responsibilities of each of the bodies mentioned above are outlined below:
CEC: The Commission has a duty under Article 30 of the Maastricht Treaty to eliminate technical barriers to trade. As such it acts under the advice of ACTE (which it chairs) to request ETSI to develop the Technical Basis for Regulation (TBR) which the Commission, acting on the advice of ACTE can transform into Common Technical Regulations (CTRs).
ACTE: It was set up under the Terminal Equipment Directive to advise the CEC in its drive towards harmonization of technical standards for terminal equipment. This includes giving its opinion on the TBR scope statements produced by TRAC and on the TBRs produced by ETSI. ACTE is chaired by the Commission and is comprised of delegations from each of the Member States. The Commission will try to achieve consensus amongst the delegations, but failing this may use qualified majority voting to reach an agreement. TRAC, ETSI and the EFTA countries may send observer delegations to ACTE who can participate in all parts of ACTE's work except the regulatory aspects. ACTE has to date held 23 meetings.
ETSI: It produces TBRs within the scope provided by the CEC based on one or more European Technical Standards (ETSs). ETSI has the responsibility of maintaining the technical sections of the CTRs. ETSI has over 300 members from all fields of the telecommunications industry and is open for membership to all countries. However, a fee is required to join and voting etc. is restricted to paid up members and is not conducted on an open international basis as in IEC or ISO.
TRAC: Develops and refines the scope statements for TBRs when requested to do so by the Commission. Its representatives include delegations from each of the Member States and from EFTA countries.
ADLNB: The Association of Designated Laboratories and Notified Bodies is open for membership to all Designated Laboratories (DLs) and Notified Bodies (NBs). The DLs and NBs are responsible for testing and type approvals of telecommunications equipment under the relevant national legislation.
MS: The governments of the Member States are responsible for establishing and regulating the Designated Laboratories and Notified Bodies and for implementing the appropriate national legislation to ensure harmonization of the telecommunications terminal equipment market. They must ensure that national testing regimes are limited to the Essential Requirements laid out in the CTRs.
Activities in European Standardization
In 1990, ETSI set up a project team (STC HF4 PT6V) to investigate the availability of standards in Europe that related to disabled and elderly people. From the large number of documents collected there were very few standards that concerned telecommunications for disabled and elderly people. This finding was somewhat surprising considering the prominence that has been given in recent years to providing measures to meet the needs of this section of the population.
The ETSI project team from its review produced the following list of recommendations for urgent consideration for standardization.
The list is in priority order and weighted in favour of comments by people with disabilities.
i) Conventional telephony:
- dialling codes, tones and signals standardized across Europe;
- keyboard layout on terminals to meet basic standards;
- inductive coupling of hearing aids to the telephone, to have standards that relate to every day use;
- sockets for additional facilities to be made available on public and private telephones;
- amplification in telephone handsets to be made available on a wider basis;
- user instructions to meet the needs of those with literacy problems.
ii) Social alarms to have standards that allow for the use of interchangeable equipment.
iii) Public access to telephones:
- access to public terminals to be easier for people with impaired mobility;
- easier use of payment cards and coins.
iv) Text telephones:
- harmonization of communication standards across Europe required to provide access to public services.
v) Videophone developments to lead to standardized interfaces and facilities for people with disabilities.
- procedures and operations to be made easier for people with disabilities (Stephanidis et al. 1994).
The ETSI report emphasized that the standardization process should concentrate on areas where specific technical solutions are possible with the involvement of user groups to ensure proper evaluation of any new standards.
Since the report was published developments have taken place in four areas, namely text telephones, immunity from the Global System for Mobile communication (GSM) phone interference, amplification on telephones, and inductive and electrical coupling of hearing aids to telephones.
The International Telecommunications Union (ITU) have produced an international standard for text telephones that provides a solution to the varied standards in existence at the moment and provides a path for future common developments. This standardization is embodied in ITU-T Recommendations V8 and V18 and is likely to be taken up by large scale chip manufacturers for incorporation into low-cost commercial modems.
ITU has also produced a Draft new Recommendation E.135 "Human factors aspects of public telecommu-nication terminals for people with disabilities" which aims in a general way to inform providers of equipment and services of good practice.
The IEC has produced a Draft Standard IEC 118-13, "Hearing Aids. Part 13. Electromagnetic Compatibility for Hearing Aids - Immunity to radio frequency fields". A second draft will shortly be circulated and it is hoped that a final version will be voted on by the end of 1995. This standard lays down levels of immunity for hearing aids which should protect users of future aids from being subject to interference from mobile phone users. It does not however solve the problem of hearing aid wearers using mobile phones.
ETSI has produced a draft standard DE/TE 04092, "Telephony for the hearing impaired. Characteristics of telephone sets that provide additional amplification for the benefit of hearing impaired persons, requirements and test methods". This standard will allow the testing of amplified telephones to take place, which has been a major stumbling block to the approval of such telephones as well as giving the technical requirements for such phones.
ETSI has also produced a standard specifying the magnetic field from telephone handsets for use with hearing aids fitted with induction pick up coils. This standard ETS 300 381, "Telephony for the hearing impaired: Inductive Coupling of Telephone Earphones to Hearing Aids", has however attracted a considerable amount of criticism from consumer groups as they were not involved in its production and the standard allows for too wide a range of field strengths to accommodate a sufficient range of users, in the opinion of many experts concerned with hearing aids.
A first draft standard DE/TE 04093, "Telephony for the Hearing Impaired: Electrical coupling of telephone sets to hearing aids", has been prepared to describe the electrical characteristics of an output socket from a telephone set. This does not describe the mechanical construction of the plug and socket at either the telephone or the hearing aid. The practical problems of connecting to the hearing aid are likely to make this approach of limited value for hearing aids but the availability of a standardized socket would be of value for other purposes.
EURESCOM, which is a research arm of the public telecommunications network operators is preparing a project in this area which will aim to identify and specify requirements and opportunities for disabled and elderly people.
Standardization is a complex and costly process which has serious consequences for consumers if the needs are not fully appreciated and taken care of. The opportunities for people with disabilities to influence standards are currently limited and means must be found to overcome this problem.
COST 219, (Eds.) Stephanidis, C., Kemppainen, E., Lindström, J-I., Martin, M. and Wiederholt, M. (1994). The Guy Cobut Report. Universal Access to Telecommunications in Europe.
Council Directive on the approximation of the laws of the Member States concerning telecommunications terminal equipment, including the mutual recognition of their conformity (91/263/EEC).
Council Resolution of 7 May 1985 on a new approach to technical harmonization and standards (83/C 136/01).
Council Resolution of 18 June 1992 on the role of European standardization in the European economy (92/C 173/01).
TIDE-HEART, (1995). User validation of requirements and testing.
SHAW, J. (1993). European Community Law. London: The Macmillan Press Ltd..