COAT Position Statement: Mandate Hearing Aid Compatibility for End-User Voice Equipment Used with Internet-Based Technologies

COAT recommendation: Extend current federal law requiring hearing aid compatibility on newly manufactured and imported telephones to end user VoIP and other Internet-enabled telephone products that, like telephones used over the public switched telephone network, have acoustic handsets or headphones and that enable voice communication over the Internet.

Who will benefit? There are over 6 million users of hearing aids and cochlear implants who need hearing aid compatible telephones in the United States. An additional 25 million Americans have some degree of hearing loss and do not wear hearing aids or cochlear implants, but may benefit from volume amplification. As increasing numbers of the baby boomer generation are projected to develop hearing loss in the coming years, this number is likely to increase.

Current law: The Telecommunications Act for the Disabled Act of 1982, as amended by PL 100-394, the Hearing Aid Compatibility Act of 1988 is codified at 47 U.S.C. § 610. This statute requires all essential telephones and all telephones manufactured in or imported into the United States to be hearing aid compatible. The mandates apply to all wireline and cordless telephones and certain wireless digital telephones. Hearing aid compatible telephones provide inductive and acoustic connections that allow individuals with hearing aids and cochlear implants to communicate by phone. To achieve inductive coupling, the telephone must emit sufficient electromagnetic energy to couple with a telecoil in the hearing aid or the cochlear implant processor. When activated, the telecoil converts the magnetic field into sound and the hearing aid or cochlear implant microphone is simultaneously turned off or reduced to eliminate or decrease any background noise or feedback that can make it difficult to hear speech. Acoustic coupling uses the microphone in the hearing aid or cochlear implant to pick up and amplify sounds from the telephone’s receiver. Under FCC rules, in order to be considered hearing aid compatible, telephones used with digital wireless technologies must also minimize electromagnetic interference, which has the effect of creating additional noise that makes it difficult to understand speech.

Why it is not enough: Recent communications with manufacturers of new Internet-enabled telephones reveal that these companies believe that they are not covered by the existing HAC mandates. The struggles to achieve universal HAC telephones date back to the mid-1970s. These struggles have entailed repeated attempts to preserve hearing aid compatibility as new generations of telephones have been introduced into the American marketplace. For example, hearing aid compatibility was threatened in the 1960s and 1970s when AT&T replaced its “U” type receiver with an “L” type receiver, in the 1980s when inexpensive phones from overseas began flooding the U.S. markets, and in the 1990s, when digital wireless devices were introduced in America. At each of these junctures, the newer phones emitted insufficient electromagnetic energy to achieve inductive coupling, provided too much interference, or otherwise posed problems for hearing aid wearers who previously had been fully able to use telephones. Federal legislation is again needed to ensure HAC access in current and future generations of Internet-based phone innovations.

Technical and Economic Feasibility: As holds true for any type of accessibility, the costs and efforts associated with incorporating HAC design will be substantially lower if this is required now, as new Internet-enabled devices are being conceived and developed, rather than later, when costly and burdensome retrofits will become necessary.

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