Paper on manufacturing for VAT purposes January 2016

The manufacturing process
for complete AT systems:
Design Objectives:
The design objectives for the AT systems that we build, based on off-the-shelf computer hardware,
are as follows:
1) To meet the communication needs of the disabled person, most typically for reading and
writing (Visual Impairment, Specific Learning Difficulties/Dyslexia, mobility issues/RSI),
occasionally for speech (D/deafness, dysarthria, CP, general learning difficulties).
2) To maximise the performance of the AT system in meeting those needs.
3) To ensure that each element works compatibly without corrupting or conflicting with other
4) To minimise the extra cognitive, time and support burden for the disabled person in using
the often complex system and keeping it working;
5) To simplify the future support process for those maintaining the system. This is usually
ourselves. In the context of the Disabled Students Allowances scheme, we have to ensure
that the student is supported for the length of their course, up to five years, in keeping the
system working on which they are so reliant day to day. This is all part of the initial sale.
The components:
Off the shelf laptop computers are today the most common hardware component for an AT System.
They are extremely powerful, low cost and very reliable. Today it is practically impossible to do
better than use branded equipment because of their economies of scale, although in earlier years
some of us assembled and branded our own hardware, which we nonetheless bought as largely
complete, if anonymous, assemblies.
However, to meet the design objective above, the computer will usually be “flattened” i.e. the
software installed by the brand manufacturer will be deleted or overwritten. (Apart from not being
suited to the needs of the disabled person, retail equipment usually contains ‘bloatware’ -- typically
trial software designed to attract add-on sales and thus improve the very thin margins for such
equipment -- which adversely affects performance.
The Assistive Technology OEM (a computer term for Own Equipment Manufacturer, someone who
assembles and usually brands computer kit) will then copy on to the system their own disk image for
operating system; security (antivirus etc); office applications; assistive technology software; OS and
other updates to date; custom desktop with relevant links to local and web based information and
help files; hidden backup for restoring the system image as originally supplied in case of severe
problems etc. Some of this may be from a standard base image, some installed from a script, some
even installed using the normal end-user process. As may be obvious, disk images and scripts allow
for a much quicker, less error-prone, more automated setup than doing normal file downloads or
copies and installation. But to set up an image requires more work and testing than just setting up
an individual machine for an individual user.
Peripherals may be added – sometimes these are zero-rateable in their own right. For example,
some specialist keyboards and Braille displays. Sometimes these are mass market printers, scanners,
multifunction printers, mice, but usually carefully selected because of specific features that make
them particularly relevant to the specific needs of the disabled person for whom the system is being
Software packages will be activated on behalf of the customer as far as possible, settings will be
tweaked to suit the particular disabled person’s needs, peripherals and their software installed and
the whole checked.
The system:
We build systems to our own design onto the building blocks of the branded computer, software
components and peripherals and with some elements of our own materials, using our own
manufacturing processes.
Although we use mass-production techniques, each system ends up more or less unique, ‘hand
crafted’ or customised corresponding to the requirements specified in an individual report produced
by a professional needs assessor for each individual student.
The manufacturing process for the branded computer manufacturers (Toshiba, HP, Lenovo etc) is
not so different. The work of assembling physical components bought from others is mostly
subcontracted. Their final software build process is not very different from ours though more
standard/mass produced and less complex. In their case the final software build will often also be
After it is built, the AT system is handed over to a disabled person at their own home or place of
work; we ensure that it is working on site as intended in the workshop; we usually have a session to
familiarise the disabled person with the system that has been prepared for them; and then further
training sessions as necessary to teach them how to use the system as a whole and the software
packages that are included in it. This training is not just to show them the features of the packages,
but to explore with them how to use the AT system to overcome their disabilities and to carry out
tasks involved in working, studying and living.
Needless to say, to buy an AT system designed and built in this way is pointless for a non-disabled
person, although the computer would still normally be usable by a non-disabled person albeit with
some inconvenience and many pointless features. But the process adds costs, in addition to that of
any software and extra hardware that have been incorporated, and of course people who are not
disabled would not be able to buy it zero rated anyway.
If HMRC accept that we are in this way manufacturing systems “designed solely for use by a disabled
person” there may need to be some revision to the process whereby we get approval for zero rating
a new product. The current process is that each new product needs clearance from HMRC, organised
by the manufacturer or importer, before the supply chain can zero rate it with confidence (when
sold to a disabled person, etc, obviously). This clearance is based on evidence from design,
manufacturing and marketing to show that the product has indeed been “designed solely for use by
a disabled person.”
This is not viable, however, in the context of complete AT systems, where individual components
change daily, and where even the central component, the computer, may change at very short
notice. However, as the number of specialist assistive technology suppliers working in that way is
relatively limited, we suggest that they can be self-certified (subject of course to VAT inspection),
perhaps with the additional measure of being subject to the Disabled Students Allowances Quality
Assurance Framework, or a member of BATA.
British Assistive Technology Association
1 December 2015