Incomplete requirements for EAA Annex I(I)(2)(j) "avoid triggering photosensitive seizures"

EAA

The product shall avoid triggering photosensitive seizures

Currently

The 2025-02-07 draft does not include a requirement for hardware to avoid flashing.

Proposed

Include a requirement for hardware to avoid flashing.

Other global accessibility standards

US Section 508: 408.3 Flashing

WCAG is not generally written to apply to hardware. However, it would be straightforward to generalise its definition of general flash and red flash thresholds based on percent of the visual field at a typical viewing distance.

I think clause 11.2.3.1 Three Flashes or Below Threshold already covers nearly every case where hardware could risk triggering photosensitive seizures. Because almost any flashing will most likely be controlled by software. Do you think there is a need for adding a similar clause as, for example, 8.6 Three Flashes or Below Threshold? In what situation could a product cause dangerous flashing that is not software controlled?

This makes some sense for the device itself.

However, we need to exclude the display of content from this requirement since there are other regulations at work there.

Devices have media players to play and stream television and movie content. The device has no way to know what is being displayed in content, and it is impossible to test a device when the content is undefined.

The concern you raise @jeffreym is not specific to the requirements about photosensitive seizures, it could be applied to most requirements.

In my opinion, the key is to know what is being tested (or designed/developed).

If the ICT under test is a web browser, I don't think any tester would require that every web page that this browser could possibly render meets all accessibility requirements. Because then, no web browser could ever pass the EN301549. There will always be web pages that will lack the semantics required by 9.1.3.1, or the alt text required by 9.1.1.1 and so on. Those requirements should be applied on the content when that particular website is tested against the EN, not when the web browser is tested.

Similarly, if the ICT under test is a media player or TV set, I don't think any tester would require that all media content that this player could possibly render meets all accessibility requirements. Because then, no media player could ever pass the EN301549. There will always be media that lacks subtitles or contain text with sub-standard contrast, or content that could trigger seizures, and so on. Those requirements should be applied on the content when that particular media is tested against the EN, not when the media player is tested.

At least that's how it used to be.

Possibly, some responsibility could be transferred from the content to the ICT rendering the content. If, for example, seizure triggering media content can be realistically detected by media players during rendering, maybe it would be a good idea to require that media players do such detection. But I doubt this is realistic.

Do you think the EN301549 needs a clarification about this?

I think we've already dealt with the other situations you mention.

For this one, I think a Note that clarifies the scope would be helpful.

NOTE: This requirement applies to those visual elements produced by the device itself. This does not apply to external visual content presented through the device, nor is the device required to examine or modify such content in any way.

added EAA Alignment label

I do not know of any hardware that flashes except under software control.

@pluke SO I think we can close this with two notes added to 11.2.3.1

Note 3: This provision applies to flashing of content on a screen and flashing of any other type caused by the software

Note 4: This requirement applies to those visual elements produced by the ICT itself. Content from an external source that is presented through the ICT, is the responsibility of the source. The provision does not require the ICT to examine or modify such externally supplied content in any way.

Regarding @gregg's proposed Note 3: This is good but it leaves a loose end. 11.2.3.1 uses the WCAG defined term 'general flash and red flash thresholds', which assumes that the flashing occurs on a screen:

the combined area of flashes occurring concurrently occupies no more than a total of .006 steradians within any 10 degree visual field on the screen (25% of any 10 degree visual field on the screen) at typical viewing distance

I believe substituting "ICT" for "screen" would convey the intent. Please include this substitution in the EN.

Regarding @gregg's proposed Note 4: I would not add this note, because I agree with @lannero's comment:

The concern you raise @jeffreym is not specific to the requirements about photosensitive seizures, it could be applied to most requirements.

@mtchllvn To clarify

You are suggesting substitution of "ICT" for "screen" in the Definition of 'general flash and red flash thresholds', -- Correct?

(if so - I agree)

RE Note 4: I would INCLUDE the note precisely because of what @lannero said. The note is there to avoice confusion -- not to exclude content presented. You can't exclude anything in a note --- only point out that it is already excluded - when there might be confusion on the part of the reader. I am ok if everyone wants to delete the note -- but I think it is useful.