On 10/26/2007, Bret McDougal wrote:


This may be a somewhat different request, but is anyone familiar with a
requirement for "bump" on the 5 key of a phone keypad.  If so, could you
point me to it.  



Hi Bret:

What countries are you concerned about?  

For just the USA, there is no regulatory requirement for the bump on the "5"
button.  As you probably know, the bump is intended to assist the visually
impaired.  FCC Part 68 does contain some specific requirements for the hearing
impaired, but nothing for the visually impaired.

The ITU publishes a variety of standards which are widely referenced in the
telecom industry.  Recommendation E.161 covers the layout of dial pads.  The
1995 edition of E.161 does not mention the bump, but in the 2001 edition the
bump has been added as a recommendation.

By themselves, the ITU standards are only "recommendations", and have no power
to regulate.  There are only two ways that an ITU standard can become a
regulatory requirement:

1) By being explicitly called out in a national regulatory requirement with
language such as "The product must comply with ITU Recommendation E.161."

2) By having a country simply transpose into their national regulatory
requirements all, or a portion, of an ITU Recommendation.


In the case of E.161, even if a country's national requirement explicitly
states "must comply with ITU  E.161," the bump would not be mandatory because
it is only a recommendation within E.161.

So, if the bump is mandatory in one or more countries worldwide, it would have
to have been upgraded from a recommendation to a requirement when those
countries transposed parts of E.161 into their national requirements.

Offhand, I do not recall seeing the bump as a mandatory requirement in any of
the national specifications that I regularly work with, but there are over 200
countries in the world and I do not have all of their specifications on file.

My guess is that you will not find a strict regulatory requirement that states
that you must have the bump in order to sell the product in a given country. 
However, the fact that the bump has appeared in ITU E.161 is indicative of a
general consensus that the bump is a good idea.  Eventually some country
somewhere may make it a mandatory requirement.




Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
781-721-2848 (USA)
[email protected]
http://www.randolph-telecom.com <http://www.randolph-telecom.com/> 

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