Section 508: Electronic and Information Technology Accessibility

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(No Transcript)
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Section 508 Electronic and Information
Technology Accessibility

• Techshare India
• February, 2008

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Overview

• Introduction
• International Harmonization
• Accessibility vs Accommodation
• Public Policy and Compliance
• Section 508 Standards
• Product Evaluation
• Overcoming Barriers to Implementation
• Resources
• Questions

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Part 1Introduction
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Overview of the Access Board

• Independent U.S. Federal agency
• devoted to accessibility for
• people with disabilities
• Small agency driven by a Board
• and managed by a staff of
• Federal employees

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What is the Access Boards role with respect to
Section 508?

• U.S. Congress assigned responsibility to the
  Access Board to develop accessibility standards
  for electronic and information technology
• We are also required to periodically review and
  amend the standards to reflect technological
  advances or changes in electronic and information
  technology
• We are currently in the midst of a refresh to the
  Section 508 standards. See http//teitac.org

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Our Democratic Rulemaking Process

• Extensive public input and involvement
• Information meetings and public hearings
• Lengthy comment periods on draft rules
• Advisory committees
• Open and inclusive
• Consultation with federal agencies, industry,
  disability organizations, and other groups
• Recommendations based on consensus

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Voting Accessibility

• New voluntary voting system guidelines issued by
  the Election Assistance Commission (EAC) include
  provisions for accessibility
• Two Access Board members sit on 2 EAC advisory
  committees, created under the Help America Vote
  Act

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Part 2 InternationalHarmonization
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Why Harmonization is Important for Accessibility

• Although Section 508 (the statute) only applies
  to the U.S. Federal government, its impact of the
  standards are being felt in state governments,
  the private sector, and around the world
• Harmonization A product can conform to 2 design
  provisions at the same time. The standards may
  differ, but do not conflict.
• It is necessary to be vigilant and committed to
  harmonization otherwise fragmented and
  conflicting standards could result in reduced
  access, user confusion, and erected barriers to
  trade
• Platform for dialoging, sharing best practices,
  knowledge base
• Global Initiative for Inclusive Information and
  Communication Technologies http//www.g3ict.com/

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Goals in the Revision Process 508 Standards
255 Guidelines

• We agree that what is needed are clear,
  consensus-driven, testable, and reliable
  accessibility requirements. In this world of
  global scales, it is critical that accessibility
  requirements be harmonized throughout the world.
  Product manufacturers want to build to a single
  set of requirements or at least not be faced
  with competing world wide requirements. We
  should do what we can to facilitate this, because
  ultimately if we can make the regulatory process
  easier to achieve and by that I do not mean
  that we need to weaken the requirements that
  exist today we will enhance accessibility for
  people with disabilities worldwide.
• Marc Guthrie, Access Board public member
• International Workshop on Accessibility
  Requirements
• Brussels, Belgium -- October 21, 2004

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Part 3Accessibility
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Accessibility vs. Accommodation

• Accessibility is technology-centered and applies
  to mainstream information technology (e.g.,
  telephones, software, websites)
• It allows use of assistive technology
• For example, accessibility would ensure that the
  agency time and attendance system is compatible,
  so that persons accommodated with screen readers
  can INDEPENDENTLY use the system to get paid
• Accommodations are person-centered and customized
  to the individual needs of people with
  disabilities
• One type of accommodation, Assistive Technology,
  requires a 508-accessible environment in order to
  work effectively
• An example of accommodation would be providing
  computer magnification software to a person with
  a visual disability

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Accessible Design Two Approaches

• Built-in or direct accessibility
• Compatible or open architecture
• AT interoperates with IT
• Electronic curb-cut analogy
• Equivalent facilitation is also allowed

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AT Complements Accessible IT(AT Assistive
Technology IT Information Technology)

• AT Screen readers/refreshable braille displays
• IT Websites and computer software
• AT Hearing aids
• IT Telephone handsets
• AT TTYs
• IT IVR/voicemail/auto attendant systems

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Part 4Public Policy
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What is Section 508?

• 508, the Law (Agencies comply)
• Applies to EIT that is procured, developed,
  used, maintained
• Goal of comparable access
• 508, the Standard (Products conform)
• Issued by the Access Board, under authority of
  the statute
• Goal To ensure that the needs of people with
  disabilities are not overlooked as we move
  forward in the information age

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Why is Section 508 Important?

• U.S. government spends 37 billion per year on IT
  
• Supports employment of people with disabilities
• Improves public access to government IT services
• Reduces the need for individual accommodations
• Encourages improvements in accessible design
• Increases availability of accessible products
• Raises general awareness of disability issues and
  promotes societal change

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Models Driving Accessibility

• United States -- push-pull economics
• Section 508 is a purchasing requirement
• Section 255 is a production requirement (telecom
  only)
• Both are enforceable by the federal government
• Natural market forces do not normally address
  accessibility thus the need for regulation
• Japan less regulation
• IT industry standards are routinely followed
  voluntarily by domestic companies
• Aging demography demands usability/ universal
  design
• Business case increase customer base

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Some Allowable Reasons for Not Providing 508
Accessibility

• Agencies are not required to incur an undue
  burden (significant difficulty or expense)
• Lack of commercial availability
• Fundamental alteration not required for
  accessibility
• National security
• Regardless of exceptions, agency obligation to
  provide accommodations always exists

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Available Remedies Under 508

• Grievances can be filed with the Federal
  department or agency alleged to be in
  noncompliance Use the administrative process for
  handling accommodation complaints
• Individuals can file private rights of action in
  court
• Outcome injunctive relief, not punitive damages
• The 508 statute requires a report every two years
  by the U.S. Department of Justice on the status
  of electronic and information technology
  accessibility in the Federal government

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Usability vs Accessibility

• Usability makes a product easier to use
  Accessibility makes a product POSSIBLE to use
• Making a product more usable does not necessarily
  lead to conformance with 508 standards
• A usability problem frustrates everyone Whereas
  an accessibility problem frustrates people with
  disabilities in particular (technological
  discrimination)
• Usability complaints may not be 508 complaints

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Part 5 508 Standards
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3 Types of Disability Access

• Communication access
• Information access
• Physical access

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Types of Products Covered Under 508 Standards

• Software applications and operating systems
• Web-based Intranet and Internet information and
  applications
• Telecommunications products

• Video and multimedia products
• Self contained, closed products
• Desktop and portable computers

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Examples of Telecommunications Requirements

• Hard of hearing Telephone amplification
  hearing aid compatibility VCO support (ability
  to talk and read with TTY)
• Deaf Pass-through of TTY signals TTY usability
  of IVR, auto attendant, and voice mail Direct
  TTY connection point
• Blindness Caller ID and similar functions
• Other Timed response warning and extension
  tactile discernability of keys

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Examples of Web Requirements

• Provide text equivalents for non-text elements
• Provide equivalent alternatives for multimedia
• Dont use only color to convey information
• Avoid blinking elements that cause seizures
• Use skip nav for ease of getting to main content
• Provide adjustable timed responses

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Many Web Requirements are not found under Web
Standards!

• For example, from software standards
  (paraphrased)
• Provide ability to execute functions from a
  keyboard
• Provide ability to track input focus
• Provide sufficient info about user interface
  elements
• Provide one non-animated presentation mode
• Provide support for color and contrast
  adjustability
• The refreshed 508 standards will clarify the
  scope of electronic content and how the standards
  apply

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Completely Automated Public Turing test to tell
Computers and Humans Apart

• A CAPTCHA is a program that can generate and
  grade tests that most humans can pass, but
  current computer programs cant pass. For
  example, humans can read distorted text as the
  one shown below, but current computer programs
  cant
• Should websites use an audio CAPTCHA as well as a
  visual one? Absolutely! Audio CAPTCHAs help
  visually impaired individuals navigate the Web.
• The CAPTCHA Project is a project of the School of
  Computer Science at Carnegie Mellon University
  http//captcha.net
• Introduction to Inaccessibility of CAPTCHA
  http//w3.org/wai/intro/captcha

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Requirements for Support Services and
Documentation

• Alternative formats for product support
  documentation
• Provide upon request (508 agency 255
  manufacturer)
• Tip Get electronic (convertible) version from
  vendor
• Description of product accessibility features
• Provide upon request (e.g., how to make a cell
  phone talk)
• Recommend providing it in an accessible format
• Accommodate disability communication needs
• Consider email, TTY, mobile texting, fax,
  Internet IM, etc
• The advisory committee will recommend that help
  desk staff also understand product accessibility
  features (above).
• Business opportunity to outsource that
  expertise?

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Part 6 Product Evaluation
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Testing Suggestions

• Ask vendors which specific 508 provisions apply
  to their products and how their products conform
• Use www.BuyAccessible.gov and request a VPAT
• Develop evaluation procedures in advance of a
  project or procurement
• Hire a consultant to train your staff on 508
• Include people with disabilities
• Dont rely exclusively on COTS evaluation tools
• Conduct periodic accessibility spot checks/audits

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Part 7 Implementation
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Accessibility Initiative

• Obtain buy-in from top leadership
• Appoint an accessibility manager
• Establish an accessibility policy
• Incorporate accessibility into the IT strategic
  plan
• Assemble an agency accessibility working group
• Institutionalize regular trainings on
  accessibility

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What Else Can You Do?

• Deal patiently with pushback, often based on
• misconceptions of accessibility as
  difficult/expensive
• Promote universal design and accessibility as a
  natural part of doing business (e.g., web
  authoring tools)
• Identify and highlight user success stories
• Reward accessibility champions (e.g., developers)
• Raise awareness publications, designated web
  page, conference exhibits, incorporate into
  speeches.

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Part 8 Resources
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How to Reach the U.S. Access Board

• Telephone
• 202-272-0013
• 800-872-2253 (toll-free in U.S.)
• Internet http//www.access-board.gov
• (Standards available in digital talking book
  format, as well as Spanish and Japanese)
• E-mail 508_at_access-board.gov

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Federal Sources of Information

• Federal Information Technology Accessibility
  Initiative STEP Tool to prioritize web
  problems
• https//www.buyaccessible.gov/index.cfm?FuseActio
  nContentID155
• Federal Communications Commission
  http//www.fcc.gov/cgb/dro/
• U.S. Social Security Administration and 508
• http//www.ssa.gov/oag/acq/oagacq_508.htm
• U.S. Postal Service and 508
• http//www.usps.com/cpim/ftp/hand/as508a/welcome.h
  tm

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Additional Sources of Information

• Research-based Web Design Usability Guidelines
• - http//www.usability.gov/pdfs/guidelines.html
• Web Accessibility Evaluation and Repair Tools
• - http//www.w3.org/WAI/ER/tools/
• Accessibility Consultant Chooser www.ittatc.org
• Industry Alliance Aims to Increase Accessibility,
  Interoperability and Innovation
  http//www.accessinteropalliance.org/

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Technology in Education

• National Center on Accessible Media
• Specifications for Accessible Learning
  Technologies
• - http//ncam.wgbh.org/salt/guidelines/
• Learning technology products database (new)
• - http//www.techmatrix.org
• National Center on Accessible Technology in
  Education www.washington.edu/accessit
• State IT Accessibility Initiatives (in the U.S.)
• http//www.ataporg.org/stateitprocurement.asp

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Part 9 Questions?
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FAQs - Web

• Do we have to remediate our legacy web pages?
• Can I write contact me for alternative formats
  instead of making a website accessible?
• Is it acceptable to summarily decide to create a
  text-only website to mirror our graphical site?
• Can I exempt a password protected site?
• Are documents created a long time ago exempted,
  even though I just posted them?

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More FAQs

• If a website works with some AT, but not all
  brands/versions, is that a 508 violation?
• Is an alt tag the only way to provide a text
  equivalent for a graphic image?
• We dont have employees/students/customers with
  disabilities, so can we take a pass on 508?
• What barriers exist in e- learning?
• What is accessible on-line collaboration?

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FAQs Multimedia Videos

• What does multimedia mean?
• What is audio description?
• What is the significance of synchronized?
• When is a transcript ok to provide? 1194.22(a)
• What is content essential for comprehension?
• What is a training and informational video that
  supports an agencys mission?
• Significance of phrase regardless of format
• What is required for live webcasts?