The intention of HAC is not to ensure compliance with network standards; but to ensure that all persons with a hearing aid have equal access to their telephony requirements at a quality that reflects the performance of persons not using hearing aids.
Consider a possible future Payphone scenario where the telephone is now a popular VoIP telephone acting as a payphone and serviced by a gateway and proxy run by a major service provider and placed in a public place such as an airport or hotel, where access is granted to all members of the public; and billing is via membership or credit card. In this instance the Gateway provides the route to compliance to the relevant clauses of Part 68, also in this scenario HAC would almost certainly be applicable, since the phone is part of the installation complete with a handset. Testing HAC isn’t impossible you should be able to test it to any G.711 64Kbit access point. Regards Carl Carl Richards, Regulatory Compliance Manager, Aspect Software 2, The Square Stockley Park, Uxbridge, UB11 1AD, United Kingdom +44 (0)208 589 1461 Office +44 (0)870 460 1950 Fax +44 (0)7875 27 1461 Mobile [email protected] www.aspect.com Unified Communications for the Contact Center _____ From: [email protected] [mailto:[email protected]] On Behalf Of Ron Pickard, RPQ Sent: 11 April 2008 01:58 To: 'McDougal, Bret (SHC US)' Cc: [email protected] Subject: RE: VOIP Phones and HAC Hi Bret, I have to disagree. My disagreement is based on the scope of ANSI/TIA-968-A found in clause 1.1. From the Scope’s opening paragraph: “This standard specifies technical criteria for terminal equipment approved in accordance with 47 CFR 68 for direct connection to the public switched telephone network, including private line services provided over wireline facilities owned by providers of wireline telecommunications. These technical criteria are intended to protect the telephone network from the harms defined in 47 CFR 68.3.” The emphasis is mine, but it clearly makes Part 68 applicable only to equipment with a direct connection to the PSTN. Remember, Part 68’s intent is to protect the PSTN from harm as is also stated in the scope. Therefore, Part 68’s requirements should not apply to VoIP phones if they don’t directly connect to the PSTN. Best regards, Ron Pickard RPQ Consulting 7372 West Luke Avenue Glendale, AZ 85303 +623.512-3451 tel, +623.848-9033 fax [email protected] www.rpqconsulting.com _____ From: [email protected] [mailto:[email protected]] On Behalf Of McDougal, Bret (SHC US) Sent: Thursday, April 10, 2008 2:46 PM To: [email protected] Subject: VOIP Phones and HAC List Members, It appears that FCC Part 68 calls for all phones to be Hearing Aid Compatible (HAC): Excerpt from FCC Part 68: § 68.4 Hearing aid-compatible telephones. (a)(1) Except for telephones used with public mobile services, telephones used with private radio services, and cordless and secure telephones, every telephone manufactured in the United States (other than for export) or imported for use in the United States after August 16, 1989, must be hearing aid compatible, as defined in § 68.316. Every cordless telephone manufactured in the United States (other than for export) or imported into the United States after August 16, 1991, must be hearing aid compatible, as defined in § 68.316. (2) Unless otherwise stated and except for telephones used with public mobile services, telephones used with private radio services and secure telephones, every telephone listed in § 68.112 must be hearing aid compatible, as defined in § 68.316. (3) A telephone is hearing aid-compatible if it provides internal means for effective use with hearing aids that are designed to be compatible with telephones which meet established technical standards for hearing aid compatibility. However I am less clear about VOIP phones, as I do not believe they are registered with ACTA. Does Part 68 apply, or is there some other requirement for VOIP phones to be HAC? Best Regards, Bret McDougal PQA & ES This message and any attachments are solely for the use of intended recipients. They may contain privileged and/or confidential information, attorney work product or other information protected from disclosure. If you are not an intended recipient, you are hereby notified that you received this email in error, and that any review, dissemination, distribution or copying of this email and any attachment is strictly prohibited. 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