Welcome everyone to today's session that is hosted by your regional Disability and Business Technical Assistance Center. This month we are talking about about accessibility in technology, specifically Section 508 of the Rehabilitation Act and Section 255 of the Telecommunications Act. This continues to be a growing issue amongst both federal agencies, public, state and local government and the private sector as technology continues to expand at light speed and we look to how we can make technology accessible to people with disabilities in the new millennium. We are thrilled to have with us today Doug Wakefield from the U.S. Access Board. Doug has been brought onto the U.S. Access Board specifically to address the development of accessibility guidelines under Section 508. As a reminder for people this session is being real-time captioned on the Great Lake web site at www.adagreatlakes.org. You can follow the links that say real-time captioning and we will also be taking questioning from the real-time captioning chat room when we open it for Q and A. Doug hello and thanks for joining us this afternoon.
Thank you Jennifer. I want to make a comment right up front that I think it is very interesting that you are doing the real-time captioning. One of the provisions that went out in our proposed rule, and I'll back up in a second but I think this is noteworthy. One of the provisions that went out in our proposed rule says that any multimedia presentations that contain audio important to the content of the program must be captioned. And we've gotten comments back and one person commented that, "Well, this means that any time an agency, somebody gives a speech or something, that has to be live captioned, that strikes me as an undue burden." Well, obviously you've just proven that it is not an undue burden to produce live captioning. And I think probably that the Department of Commerce or the Department of Education or the Department of Transportation probably has more money than Jennifer's agency.
Anyway, let me back up. 508, 255, all kinds of numbers. They basically refer to different pieces of legislation. 255 is a section in the Telecom Act that was passed in 1996 that authorized the Access Board to develop access guidelines for telecommunications equipment.
Section 508 actually is an amendment to the Rehabilitation Act of 1973, and 508 as an amendment has been around since 1986. At that time the amendment strictly said that the General Services Administration's administrator and the Secretary of Education would develop guidelines that would ensure accessibility to information for people with disabilities. And that literally was it. It was about a paragraph and there was no enforcement, there was nothing as to how those guidelines would be applied or what would be expected to be accomplished.
In 1998 there was a new amendment and that is what we are talking about now, 508 reborn really. This time it has been born with some teeth and there is an enforcement provision. I want to talk about the law itself before I talk about the the the provisions we are working on, because I think it is very important to get some concept of what is covered by 508 and what the goal is.
First of all, 508 is not hard reading, if you run across it. Or you can look at the rule on our web site at www.access-board.gov. 508 is a short document that states that when the Federal Government, and it only applies to the Federal Government, agencies that are within the executive branch. It doesn't apply to the legislative branch. It says that when the agencies procure, maintain, use, or develop information technology, the technology is to be as accessible to individuals or employees with disabilities as it is to employees without disabilities. Then it goes on to say that when agencies provide information to the public, that information must be as accessible to members of the public with disabilities as it is to other members of the public without disabilities. Of course, that key phrase there "when they provide information to the public" is what got us into the whole arena of web accessibility.
Now, what is important here is when it says that when it procures, etc, etc, etc, information technology, it is not talking about buying screen readers and TTYs and special one-handed keyboards. This applies basically to just about all electronic and information technology that is used in the office, that is used to dispense information. Maybe it is a kiosk, maybe it is a web page. And this is what gets very tricky, it is not about assistive technology. It is about working with assistive technology. Of course this raises some interesting questions about "what is accessible?"
If you have a computer on your desk and somebody who is visually impaired comes up to use it. Let us say you have 20/20 vision and no disabilities whatsoever. Somebody comes up to use your computer, that computer as it sits there is not accessible. However, under our standards that we are writing it is accessible. Sounds confusing. It is similar to somebody going to a building and they are a wheelchair user. The building is accessible to them using the wheelchair. An accessible building does not mean that you park your wheelchair outside and can travel through the building because it is accessible. It is accessible to the chair. So information technology must be accessible to assistive technology is probably the easiest way to say it. This law is not focusing on purchasing assistive technology. It is focusing on the environment that needs to be created so that when agencies under reasonable accommodation purchase assistive technology, that technology will work.
Many of us have been in situations I'm sure where you go to install something or help somebody with something and you run into these nightmares of compatibility and incompatibility that really aren't necessary but they have been brought upon by people buying a variety of systems that they didn't know wouldn't work with this or that particular piece of technology. I think one of the assets to this rule is that it will make technology in general work better.
Good example. I used to work for the Center on IT accommodation over at GSA. We got a computer in, new computers, fancy. I think at that time these were 486s, they might even have been 386s, and we put in a satisfaction 400 card. This was an old modem board that ran at the lightening speed of of 14-4 and also was a fax. We put a couple of those in the computer, turned the computers on, and it said "no hard disk installed," no operating system. Pulled the card out and it worked. Well, we couldn't get anybody's attention with this for a while, couldn't figure out what the problem was. We knew pretty sure it was what is called an interrupt problem. In other words, a conflict of resources, and we finally got to some higher ups in the procurement section and in the information resource management section and they were having trouble, it turned out with a sound blaster card. Somebody wanted to put a sound blaster card in his computer and when he put the sound blaster card in it said "no hard disk installed," no operating system available. He was having exactly the same problems that we were having with the modem card. We did some checking and somebody else had tried to put in a deck talk speech synthesizer card and they ran into the same problem. In their case the vendor they contacted, the mainstream producer of the computer said "Well, that is your assistive technology. It is obviously not our problem." Well, here we had a modem that wouldn't work, they had a sound blaster card that wouldn't work and so we knew for sure that we had a conflict within the computer itself. And I think that when systems are designed to be more accommodating of assistive technology, there is nothing that is special about assistive technology when it comes to interacting with computers. They are just like any other any other peripheral. So I think you are going to find a more forgiving environment for all kinds of additions that people may want to add on or use in the office. So that is one of the benefits that I think everybody will see from 508 in the government.
There is another benefit. The government is a big, big, big customer, and this is one of the big differences between the the Telecom Act, Section 255, and Section 508. The Telecom Act basically sets guidelines for manufacturers to follow when designing or developing equipment. Section 508 sets standards to be followed by procurement officials within the government. So instead of starting at the manufacturing end and the beginning of the product development cycle, 508 really starts at the other end in terms of "Here is what I'm looking for, do you have it available? And if you don't have it available will you have it available by the time the solicitation must be completed?" And so it is a market driven situation and this is, as I say, totally different than 255.
What this has brought about is with the Telecom Act we could have quite general guidelines that were very performance based; in other words, it must be usable without vision. If you have a provision like that, it must be usable without vision in 508, you kind of have to go a little bit further too because that doesn't give procurement people much to go on when buying something as far as standards. So unlike the Telecom Act, which can be very performance oriented, and we really don't care how the manufacturer achieves the end result, as long as it is achieved. The procurement people need things that they can measure. They need to be able to specify what something needs to do before it is going to be bought and not just performance but some very specific statement of how to meet a particular standard. This has been tricky because a lot of things to do with accessibility really are hard to measure, as you know, and so how do you measure?
Now, fortunately, there is something coming up that is going to change this. But you remember, if you've looked at the Telecom Act there is a statement in there that says that the off-the-shelf equipment should not interfere with hearing technology, in other words, it shouldn't cause things to buzz and hum and click. That interference should be reduced to the lowest possible measure. That is an unmeasurable statement and maybe one company could reduce it X amount and somebody else could reduce it twice as much.
Fortunately, the ANSI committee is just releasing, it is got to go for public comment, but it has done basically some real standards for purchasing telephones as well as hearing technology so that you can get some degree of predictability as to whether or not there will be interference with this or that particular product. And this is what we'd like to see more of is ways to measure accessibility.
I do want to give you some actual statements as to where we are. The one thing that I've been absolutely amazed on with 508 is how people make up dates that things are going to happen. It is just incredible the dates that people come up with that "I've heard you are going to release standards" ...the last one I heard was somebody over the FCC said "Oh, we heard you are going to be publishing on December 7th, is that true?"
No, I do not believe that we are publishing on December 7th. I have no idea where that date came from. The original legislation said that the Access Board, 18 months after enactment of the law, which turned out to be August 7th, 1998, within 18 months, by February 7th, the Access Board would publish standards. So obviously we didn't make our publishing date of February 7th and most people felt at the time that knew what was involved that this was going to be a very difficult, if not unrealistic goal. It just takes longer to develop standards to go through the review process, to get agreement from various sectors, but anyway we finally, as you know, got our proposed rule out for public comment on March 30th and it was out for 60 days.
You might find it interesting, we received 104 comments. Approximately 40% were from government agencies, which is probably appropriate since it does affect the government most directly. Then we've got 33 comments, 32%, from either individuals with disabilities or groups that represent individuals with disabilities, such as National Association for the Deaf, Telecommunications for the Deaf Inc. American Council of the Blind, American Foundation of the Blind. These are the different advocacy groups or organizations that commented. We got about 16 from industry and then we received eight comments from individual state associations such as the state IT accessibility coalition or the Massachusetts Assistive Technology Program, commenting on applicability to the states.
So before that question comes up, why don't I address it. The answer is "I don't know." The question is "does it apply to states?" What is going on is this: the Department of Education has originally ruled that when a state receives money under the Tech Act that all components of that state must comply with 508. Well, there is a couple of issues there: all of a sudden slapping a regulation on states without giving the whole state government a chance to react and comment. That is our whole comment period here, of course, we don't do regulations without public comment first. And the other issue, of course, is it could change the cost of the rule considerably if we said "now it applies to every state and every component of every state that gets the Tech Act funds." This is a debate and a call for the Office of Management and Budget and the Department of Education. People ask us a a lot what is our opinion or what is going to happen? Basically, we don't know. It is not up to the Access Board to make this call. Obviously, we want to see 508 implemented as widely as possible, but we also know the realism of saying that a state's budget has got to be increased by X million dollars to comply with 508 because an agency received $100,00 for a small tech center. As one commenter said, "Basically a state could decide that they really don't need that center that badly." And we would hate to see the Tech Act projects basically shut down by individual states because in the end they were going to cost them too much money.
We had the comment period as I mentioned. We got eight comments from states about applicability to the states. The comment period closed on May 30th and we are now writing the final rule. While we were doing this the Congress passed something called the Military Construction Act, which was a gigantic bill and had over 100 irrelevant amendments attached to it, irrelevant to military construction that is. But when you've got a big bill like that if you want to get something through without much discussion, it is a good place to hide it. So Congress decided that that would be a good place to put an extension for 508 that wouldn't be quite as noticeable as debating it as a separate rule. And what they did is pass an amendment that says that six months after we, the Access Board, publish our final standards, the enforcement will kick in. This basically gets it back in line with what the original intent was. I said, we were to publish 18 months after the law was enacted, and then six months after that the federal acquisition regulation folks were supposed to incorporate our regulations into their handbook, into their set of what they call the FAR, Federal Acquisition Regulations and it is a big book of everything from how much percentage must be small business, how to handle contract disputes, now it is going to have something for the requests for proposals to incorporate the accessibility standards when purchasing information technology. So we hope to publish by the end of the year.
We really want to publish before there is any change in the administration. It is not so much tied to who wins, but whenever there is a change of administration sometimes what happens is the new person coming in says "Well, maybe we ought to put all regulations that are being done right now, let us put them on hold and take a quick look at them before we proceed." The other bigger problem is that all the cabinet members resign, even if there is not a change of party, all the cabinet members resign and some get reappointed. But we do have an ad hoc advisory committee helping us with the final rule that is made up of five agencies, and these are pretty high level people that are appointed by the secretary or assistant secretary. This could put quite a quash on our meetings if all of a sudden our representatives change on us because their bosses have left. So we just would like to get this done as soon as possible. So that is where we stand there.
A final note before we open it up to questions is about enforcement. Drawing a comparison between the Section 255 of Telecom and Section 508. First of all, enforcement under the Telecom Act said that a company or manufacturer had to comply with the guidelines if it was readily achievable, which means no particular expense and not inconvenient. Also, if somebody has a complaint against a manufacturer and they want to complain under the Telecom Section 255, they have to contact the FCC. They cannot file a direct civil rights or civil complaint. They go to the FCC and the FCC are the only ones ones that can actually file any action against a company or try to contact the company and find out why aren't you in compliance. And there is all kinds of rules as to how long the company has to reply and so on or are you sure this is not readily achievable and if the company proves it is not readily achievable then it is basically a dead issue.
Section 508 says that an agency in order to not comply must prove it is an undue burden to comply. The individual, whether it is an employee or it is an individual in the public seeking information from the government, say, in finding the information systems inaccessible, basically follows the same rules as Section 504, and that being that access to programs and services. It is handled by the 504 coordinators that have been in place for many years and the rule actually states, the 508 legislation says that grievances will be handled following the practices developed under 504. So there is the mechanism already in place. We don't believe that it is a matter of, "You denied me access, I want $100,000." Now, it will be basically "You denied me access, I want you to fix it" and if the person wins the action, then yes, the agency has to fix it. Let us open it up for questions.
I'm going to ask the first question because Doug, you know we've talked about this back in February or so and I was preparing to do a training session on Section 508 and 255 and, you know, being a trainer for almost eight years now this is definitely the hardest topic that I've had to prepare for and you were very helpful. Let us get kind of to the basic of it. 508, what does it cover? What is electronic and information technology? Just because I plug it into a wall and it is electrical doesn't necessarily mean that it is covered; is that right?
That is right. In the proposed rule one of the things, Congress does some unusual things sometimes and in this case they said "We want you to write access standards for electronic and information technology and oh, by the way, would you define electronic and information technology before you write standards for it." So we did write a definition of electronic and information technology, but we had to be consistent with an existing definition of information technology. Wou have to look at what the product does. Does it store or transmit or duplicate or convert? Does it manage or manipulate information, either receiving it, taking it from place to place, or displaying it? One of the exemptions that is in the Federal Acquisition Regulations that we have to adhere to because they have the final word on procurements is, if something has what is called embedded information technology, and they give the information of heating and ventilation and air conditioning, that obviously uses information technology inside. Everything uses computer chips these days, including your car. But the end product, the end result is not to communicate information or gather information from people. It is to control the environment and the information technology is embedded in it. So a microwave oven, although it has plenty of information technology in it, its end goal is not to process information, it is to melt butter and I think that is probably the best way to look at it. In categories you can say that it covers all software, it covers all computer hardware, it covers everything from hand held calculators, floor standing printers, copiers, web pages, information kiosks.
So if I have an electric stapler, the end result of that is not to give out information.
That is correct.
Okay. But, now this is where I think that we had a little bit of discussion was, if I am a federal agency that has a lodging facility and I'm using, say, alarm clocks in every one of my guest rooms. Covered? Not covered?
Not covered under 508. Certainly covered under plenty of other provisions.
Possibly under 504 just in the respective program access.
Yes.
Okay. Now, the difference between 508, if we flip over to Section 255 under Telecommunications. Section 255 we are basically talking about telephone equipment, right?
Yeah, what they call customer premises equipment.
So anything that the consumer actually uses, and so that would also encompass cellular phones; is that right?
Yes as long as it is... you know, I ran into this. Cellular phones, but in theory not these little hand held radios like I have a set of these Motorola, what they they call "talk-abouts."
The little walkie-talkies.
Yeah, they have a transmission distance of about a mile to two miles, they are really nice but they are not on a network and so in theory they are not covered.
Because they don't use the telephone circuitry.
Right.
Great. Kathy do we have our first question out there?
Good afternoon this is Mark Snow. I have two questions related to Section 255. One is does that only apply to things that are manufactured in the United States or does it apply to things that are sold in the United States. Second question is the definition of readily achievable under Section 255, is there flexibility in that definition in that if technology changes so that what was once not readily achievable becomes readily achievable, does the standard change? Thank you.
Okay. I'll tackle the second one first because that is the easiest. Technology, whether it is 508 or 255, is changing rapidly, and what is an undue burden today or what is not readily achievable today may be readily achievable tomorrow and won't cause an undue burden either. The standard doesn't change, it is, I always use the term "the bar has raised." In other words, you have to do more before you can say it is not readily achievable, more is possible. It is sort of like raising the bar of web access, you know, how low do you have to make it, does somebody have to be able to use it with just a dummy terminal or do they have to be able to use an XT or a 386 or a Pentium and do they have to have the latest and greatest browser or do they use a text-based browser? How high do you set the access bar? And readily achievable is a very low bar to jump over and how you define that bar will constantly be changing, but it will always be readily achievable as the measurement, and the same with undue burden. As technology advances undue burden will definitely change. As far as your first question, I believe it is what is sold. It is definitely what is sold because a lot of our equipment is, as you know, manufactured, as they say, offshore, and it would just exclude so much product if it only covered what was manufactured here.
Thanks Doug. Another resource that people might want to look at, especially when it comes to Section 255 and different types of product is the Trace Research Center at the University of Wisconsin. They have done a couple different research projects and papers on the different types of features that when you are purchasing that type of telephone equipment that you can look to to see whether or not that telephone equipment includes it.
This is actually Denise Thompson at the same site in Phoenix, Arizona. I have a question going back to what you talked about earlier, Doug, the running real-time captioning. If this does not apply to the legislative branch, then that means that information that is just streamed out to the public, for instance, like on the C-Span channel or, for instance, our own state legislature, if they have an Internet connection where they just have it open and you can just listen into what is happening in the legislature that day or whatever, those types of medium would not have to be captioned; is that what I'm understanding from what you are saying?
In general I think your interpretation is correct. However, it is kind of interesting. When the Rehab Act was passed in 1973, even then it only applied to the executive branch of the government. The Congress exempted themselves. When they passed ADA they said "gee, we hadn't better exempt ourselves again." So Congress and the legislative branch of the government is covered under ADA; the executive branch is not. The executive branch is under the Rehab Act. So in terms of providing access to services, I'm sure somebody out there, probably Jennifer is more of an expert on ADA than I am. What is it Title II or one of those?
I would say that while they would not be covered under Section 508 that they certainly could be under Title II or under the program access requirement for the ADA.
That is exactly what I was going to say. Because Congress is under the ADA.
So the point of it is that while they might not necessarily be covered under 508 directly, that there could very likely be other legislation that would umbrella their service.
I think that question raises an interesting point because we had talked about earlier how much attention web access has gotten through 508 and through the the ADA in a lot of lawsuits that are coming up, you know, those against AOL and similar type sites and that, is that the web now is not just a linear platform, that it is become much more interactive. And the issue of when we do something that is multimedia like the chat room that we use today for the captioning, of also looking at what other media could we use to make sure that this is accessible for other groups, for other populations of people with disabilities?
Yeah, it is one of those, especially the Internet, things are going to have to have to be redefined. We said earlier technology is advancing so fast and we said that it used to be that, well, an Internet site wasn't a store, wasn't a place, wasn't a built environment, therefore access to it wouldn't necessarily be covered. We have in this area now, I know it is also in Illinois and there are several others around, we have an on-line grocery service that is totally on-line. You can't call and place an order, you can't go there. It is all on line. And it is one of the hardest sites I've ever seen for somebody to use with a screen reader. Now, are they actually a facility? Or are they not covered? As I say, I think we are going to have to redefine what is built and how we perceive, basically, the environment and making it accessible.
Great. Thanks Doug.
Yes. Today we were talking about computer technologies and programs that use voice recognition. There are programs that use voice recognition or change text to voice. Do those kind of things have to be covered with these laws, as far as being able to respond to those?
Most definitely. Somebody who either for some reason is unable to use a voice input system or that wouldn't be able to get information from a voice output system, under 508 must be provided, the system itself must provide an alternative. It can't rely on just one method, whether it is input or output.
Great. Thanks Doug. Our next question Kathy.
This is Craig Smith speaking and I'm very interested in the ANSI specs on telephones. I noticed there has been some problems with FCC applications actually interfering with the importation of superior interfaces for people with handicaps. EIA was implemented as law in the year 2000, January 1, despite the fact that that standard provided for the spec in 1997 to EIA 504 A. I gather from following the issue that the EIA was aware of that and that and that they have been working on making a specification that will put an upper limit on the emission of that device that meet that EIA standard. Is there going to be a conflict because at this time the FCC prohibits importation of phones from other countries that have better standards, quite frankly. Is EIA going to coordinate with the FCC?
This is something that is outside of my current realm of expertise. I've got a hunch I'm going to learn a lot more about this in the next six months, but I would have to turn around and contact some people, one of the best groups to be in touch with if you are interested in this sort of thing is a new group that came out of the telecom called AAES, and it is Association of Access Engineering Specialists.
And as far as selling or buying, is there a loophole that will allow you to buy superior equipment in Europe and bring it into the United States, or is there a definition of where the point of purchase is.
Not that I'm aware of. You mean for telecom?
In other words, you might find products that are superior not hung up on the problems that EIA 504 created. Can you go to Europe, buy that, bring it to the United States?
I do not know.
So as far as the issue of whether you buy it in the United States or it is manufactured in the United States, is there any literal definition? Sounds like it is buy it in the United States. Is that written down somewhere?
In the telecom it is talking about when something is manufactured, and if it is manufactured out of the country it basically is talking about the product that you sell, whether you manufacture it yourself or you have somebody outside manufacture it.
Thanks for your question.
I wanted clarification of exactly which groups were covered under 508. Are they the same groups that are covered under 504? In other words, would state universities receiving federal funding or any agency federal grants or contracts be covered so that if a university, for example, wanted to procure equipment, they would have to meet these standards and guidelines for their computer technology?
No. 508 only applies to federal agencies. The only fudge area is states receiving Tech Act funds and whether you would consider a state university a component of the state and whether or not the U.S. Department of Education is able to have their particular ruling stick that if the state receives Tech Act funds then all the components. Right now totally hinged on the Tech Act, but as far as, you know, grants and so on in 504 and anti-discrimination, it is not tied in that at all.
Doug, would there be a possibility that individually from agency to agency that that might be a stipulation that could be included as a stipulation of receiving the funding that they would need to look at electronic and information technology and that which was newly purchased being accessible?
You mean in other words let us say Department of Commerce makes the decisions that the people who receive certain grants...
Okay. It would be unlikely. It is possible, but you see, there is this whole thing of what they call federalism that has to do with the fact that the government, in theory, is not supposed to slap a requirement on states without first going through a process of proposal and comment. So states would have a right to comment on whether or not they thought this was a reasonable requirement.
Okay. Good. Thanks Doug.
Hi, can you quickly repeat what AAES stands for?
AAES is the Association of Access Engineering Specialists.
Kathy, one more question then I'll turn it back to you Doug for closing comments.
Hi, this is Olle Canter, with the Disability Center for Western Rights. With regard to palm pilots would that fall under 255 or would it fall under 508.
That is 508, that is definitely a executing piece of equipment. It can be used as telecommunications and there is always been this sort of gray area of when something is used to conduct a telecom service, such as e-mail and so on, but FCC has not come down very solid on covering e-mail and certainly not covering products that can receive e-mail. So palm pilots would definitely be under 508 with absolute certainty.
Great. Thanks Doug. You've been a wealth of information today in a short period of time. Going to turn it back to you if you have a brief closing comment for us.
Okay. The only thing that I would would say is that although we received 104 comments probably there were a lot more than 104 people or groups that were interested, and what I have found and what I've learned, being in the government and being involved with rulemaking, is that you are not sending comments into a black hole. When you comment on rules, you are actually going to have your comments read by individuals who are making the decisions and looking at your comments very thoroughly. So the one thing I would say, and this sounds like real old, old hat, you know, high school civics, but I've never been quite as impressed as I have been lately with the need for individuals or groups to actually participate in this process, because despite what you might think, you might think one vote doesn't change an election, but I can tell you one good comment can change a regulation. And we don't have our final regulations out yet, but if you want to have some fun trying to predict how our proposed rule and our final rule might be different, what you want to do is go to the web page that I gave you before for the Access Board, and look at the comments and look at those sections that have the most comments and when there is a lot of comments or some very articulate individual has written, chances are we are looking at that awfully hard and are going to do
Great.
I want to say thank you.
Thanks so much for joining us today Doug. You have been a lot of information in a short period of time and we will have the transcript from today's session posted up on the web site next week, along with all of the resource web links as well. There are links already to the Section 508 overview, also to the FCC and their new Office for Disability Rights that people will definitely want to take a look at as well, as they have a lot of new resource information for consumers coming out of that. And you also have plans when the final rule has been issued to develop resource materials or guidance materials; is that right?
Very definitely, yeah. One of the things, we are given the job of providing technical assistance.
So you'll have a lot of work coming up in 2001. We'd like to thank everyone for joining us today. Next month's session will feature Access to Air Travel, as we all get ready for travel during the holiday season. We'll have Bob Ashby from the U.S. Department of Transportation who is general counsel there talking a little bit about the interplay between the Americans with Disabilities Act and Air Carrier Access Act. So we hope to have you back for next month's session. And for those of you that have more questions after today's session please call your regional Disability and Business Technical Assistance Center at (800) 949-4332 as they have technical assistance specialists on staff to help you with your questions.