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Section 508 for Beginners

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What is Section 508? Part of 1973 Rehabilitation Act, as amended in 1998 ... Section 508 USPTO Process Hardware and COTS Micro-Purchase Software Web Training ... – PowerPoint PPT presentation

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Title: Section 508 for Beginners


1
Section 508 for Beginners
  • 2008

2
What is Section 508?
  • Part of 1973 Rehabilitation Act, as amended in
    1998
  • Provides comparable access to those with
    disabilities as to those without
  • Includes any Electronic Information Technology
    (EIT) that is developed, procured, maintained or
    used by the Federal Government and the US Postal
    Service
  • Law with teethGovernment can be sued

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
3
Why Enforce the Law?
  • Obviously, It Is a Law
  • It is the right thing to do
  • An agency can be sued and systems can be pulled
    out of production
  • Supports Federal and State initiatives
  • Presidents Management Agenda
  • New Freedom Initiative
  • You have a vested interest

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
4
Why Enforce the Law?
  • Do you have problems with?

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
5
Why Enforce the Law?
  • Do you have one or more of the conditions
  • listed on the previous slide?
  • what about family members?
  • or your friends?
  • or your co-workers?

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
6
U.S. Census Data 2006
  • These numbers are approximate as of the American
    Community Survey, 2006
  • 41.3 million people with some type of
    long-lasting condition or disability
  • 11.8 million people with sensory disability
  • 25.7 million people with some type of physical
    disability
  • 15.9 million people with mental disability

http//www.census.gov/hhes/www/disability/2006acs.
html
Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
7
Dissecting the Law
  • Law consists of three subparts
  • Subpart B - Technical standards for six
    categories of products
  • Subpart C Functional performance criteria
  • Subpart D - Information and documentation
    requirements

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
8
Dissecting the Law
  • Subpart B consists of standards for
  • Software applications/operating systems
  • Web-based information and applications
  • Telecommunication products
  • Video and multimedia products
  • Self-contained, closed products
  • Desktop and portable computers

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
9
Dissecting the Law
  • Subpart C
  • Technologies or components for which there is no
    specific requirement under the technical
    standards in Subpart B
  • Covers operation, including input and control
    functions, operation of mechanisms, and access to
    visual and audible information

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
10
Dissecting the Law
  • Subpart D
  • Consists of information, documentation and
    support
  • Requires manufacturer upon request, to provide
    compliant electronic text for all documentation
    associated with the product

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
11
Dissecting the Law
  • When determining the appropriate standards to
    use
  • More than one category of standards may apply
  • Not all the standards in a category are
    necessarily applicable

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
12
Dissecting the Law
  • Technical Requirements drive the procurement, not
    Section 508
  • Legal liability only pertains to the Procurement
    of IT, Services and Maintenance
  • Federal Government is liable for non-compliance,
    not the contractor or manufacturer

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
13
An Example of a Best Practice
  • US Patent and Trade Office
  • Their Process
  • Their Program
  • Their Training
  • Common Requirements
  • Hardware and COTS

14
USPTO 508 Processes
  • USPTO has processes for the following
  • Purchase of IT Hardware and COTS Products
  • Credit card Purchases of IT Products
  • Development and Maintenance of IT Software
    Systems
  • Creating or Maintaining Web Products

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
15
USPTOs Section 508 Program
  • Staff available to help at any time
  • Features include
  • Assistance with procurement
  • Consultation and testing during all phases of
    product development
  • Testing before product deployment
  • Training classes
  • Evaluation of latest technologies

16
USPTO Section 508 Training
  • Training classes offered at USPTO include
  • Writing accessible documents
  • Authoring Section 508 compliant web pages and
    applications
  • Developing compliant software
  • New and emerging technologies including AJAX and
    Flash

17
Common Requirements
  • Person buying or creating a product signs a
    checklist certifying compliance
  • USPTO interpretation of Section 508 is based on
    the Letter of the Law, not the spirit of the law

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
18
Common Requirements
  • Check-and-balance
  • Non-compliant products will be pulled from the
    internet/intranet or stopped from going into
    production or returned to the vendor
  • Only Section 508 Coordinator can authorize
    exemptions or waivers

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
19
Hardware and COTS
  • Includes IT Hardware and COTS products and
    services
  • Product Purchaser is responsible for compliance
  • Of vendors who meet the functional requirements,
    determine who best meets the applicable Section
    508 standards

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
20
Appendix USPTO Forms
  • The following slides contain samples of
  • forms used by the USPTOs Section 508
  • program.

21
EIT Procurement Checklist
Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
22
Purchase Card Pre-Purchase Worksheet
Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
23
AIS Checklist
Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
24
USPTO Accessibility Office Information
  • In the USPTO, the Accessibility Office is
    responsible for all EIT 504 and 508-related
    actions plus product evaluation and determining
    compliance
  • If you would like more information about the
    USPTO Section 508 Program you can contact
  • Joyce Miller
  • joyce.miller_at_uspto.gov
  • 571-272-5422

25
What is Market Research?
  • The act of collecting and analyzing information
    about capabilities within the marketplace to
    satisfy agency needs

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
26
Why Conduct Market Research?
  • FAR Requirement
  • Used to gauge the state of the EIT industry in
    meeting your requirements with products and
    services
  • Method for identifying products that meet Section
    508 requirements

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
27
Market Research
  • Requiring Officials determine technical
    requirements
  • Identify products that meet those
    functional/technical requirements
  • Send appropriate 508 checklist to vendors who
    have the products
  • Take the stand that only vendors who provide
    completed checklist are eligible for contract
    consideration

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
28
Informal Market Survey
  • Vendor Internet site
  • Review of similar procurements by other agencies
  • Catalogs, product literature
  • Scientific journals
  • Business publications

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
29
Formal Market Survey Techniques
  • Using a published vehicle
  • Sources-sought announcements in the Federal
    Business Opportunities (www.FedBizOpps.gov)
  • RFI (Requests for Information) for planning
    purposes to gather appropriate technical
    information, approximate cost, and schedule
    information

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
30
What is the Buy Accessible Wizard?
  • The Buy Accessible Wizard is a web-based tool
    that
  • Guides users through the acquisition process,
    gathering data and providing information about
    electronic and information technology (EIT) and
    Section 508 compliance
  • Compiles a running summary documenting the
    process and its results
  • The Buy Accessible Products and Services
    Directory
  • Access to vendor provided accessibility
    information
  • The Buy Accessible System makes compliance with
    the requirements of Section 508 as easy and
    thorough as possible

31
Who Should Use the Wizard?
  • Micro purchasers (IT) with government purchase
    cards
  • Program technical specialists (IT) that determine
    acquisition requirements
  • Program requirements officer responsible for
    program requirements documentation development,
    consolidation
  • Contract officers that specify (IT) requirements
    on behalf of agency programs

32
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33
How Can the Wizard Help Your Agency?
  • Standardize the process you use for each
    acquisition.
  • Document your procedures to demonstrate due
    diligence
  • Maximize market research. Use vendor-supplied
    accessibility information about the commercial
    availability of accessible EIT products and
    services prior to solicitation.
  • Tailor your solicitations. Ensure there is
    specific Section 508 language in each
    solicitation that includes EIT.
  • Require accessibility information.
  • Document accessibility as a factor in source
    selection
  • Document accessibility as a factor in inspection
    and acceptance

34
Be Our Guest for a Test Drive
  • We invite you to test drive the Buy Accessible
    Wizard Release 3
  • To access the Buy Accessible Wizard Release 3 go
    to http//www.buyaccessible.gov/ and use the
    Guest User login

35
The VPAT and Market Research
  • Voluntary Product Accessibility Template
  • Completed by the Vendor
  • Information on how a product or service conforms
    to the Section 508 Access Board standards
  • Optionally, posted on their vendor site and
    linked to Buy Accessible Wizard Tool
  • Vendors are not required to complete a VPAT

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
36
  • Examples of VPATS

37
Adobe Dreamweaver CS3 VPAT
  • Date 3/30/2007
  • Name of product Adobe Dreamweaver CS3
  • http//www.adobe.com/resources/accessibility/tools
    /vpat/dreamweaver_cs3_508.html

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
38
Mozilla Firefox 3.0 VPAT
  • Date 06/10/2008
  • Name of Product Firefox 3.0
  • General Comments Information in this VPAT is
    relevant to Firefox 3.0 running on a Windows
    2000, Server 2003, XP, or Vista operating system.
    Additional developer tools exist in this product
    that are not installed by default. These optional
    tools have not been tested.
  • http//www.mozilla.com/en-US/firefox/vpat-3.html

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
39
Sample Source of VPAT Information Used by the
USPTO
  • http//www.evengrounds.com/resources/vpat-director
    y
  • Contains a concise list of companies with VPATs
  • Companies can be added to the list
  • Further information on what is needed in a VPAT

40
Tips for Selecting a Vendor
  • Review vendors checklist
  • All standards are equal in importance
  • Do NOT accept yes, a checkmark, or meets
    standards
  • Need more information to make informed decision
  • If unsure, ask vendor for more information
  • Since vendor claimed compliance, they should have
    information readily available

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
41
Tips for Selecting a Vendor
Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
42
Tips for Selecting a Vendor
  • Review Possible exemptions
  • Check with the agencys appointed authority
  • Exemptions include
  • Back Office - Equipment or software which resides
    in a data center or communication closet that
    cannot be readily accessed or accessed remotely
  • Fundamental Alteration - altering design and/or
    alteration of the function of the device or
    operation

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
43
Tips for Selecting a Vendor
  • Review Possible exemptions
  • Commercially non-available at time of buy
  • Support Maintenance agreements
  • USPTO Position - There is No Such Creature called
    Undue Burden or Deferred

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
44
Tips for Selecting a Vendor
  • Complete processing procurement request
  • Consider a Sole Source purchase
  • Buyer completes checklist and signs it,
    certifying Section 508 compliance

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
45
Tips for Selecting a Vendor
  • Complete processing procurement request
  • Section 508 Coordinator reviews and initials
    procurement checklist
  • Buyer processes request with the checklist and
    supporting documents
  • Market Research
  • Most Compliant Vendor
  • Sole Source Justification

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
46
Micro-Purchase and Section 508 Purchase Card
Program
  • Effective April 1, 2005 all purchases of
    electronic information technology (EIT) products
    must comply with Section 508 requirements
  • This includes (1) GSA schedule purchases, (2)
    open market purchases and (3) buys that cost
    3,000 or less

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
47
Requiring Official's Responsibilities
  • Understanding the Section 508 requirements and
    requesting products that are Section 508
    compliant
  • If a product does not conform with Section 508,
    it still may be purchased, but the file must be
    documented in accordance with the exceptions
    listings for Section 508 requirements

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
48
Approving Officials Responsibilities
  • Ensure that the purchasing cardholders within
    their organization are complying with the Section
    508 requirement
  • Review any documentation that has been provided

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
49
Purchase Cardholders Responsibilities
  • Ensure all necessary documentation has been
    reviewed and completed before purchasing any EIT
    products

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
50
Developing Software
  • Writing the code for a new or revised system,
    makes it difficult to claim any type of exemption
  • Retrofitting a system for compliance is extremely
    expensive
  • A system should not go into production if it has
    Section 508 deficiencies

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
51
Developing Software
  • Most Section 508 standards are simply good old
    coding practices
  • Always code to the standards and not the
    accessibility tools (e.g., JAWS, Dragon Naturally
    Speaking)
  • Currently, there are no tools designed to
    evaluate software automatically

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
52
Developing Software
  • If JAWS can read a program, that is no guarantee
    that it is compliant
  • If JAWS cannot read a program, that is no
    guarantee that it has deficiencies
  • Few sighted people have sufficient expertise with
    JAWS to use it as an evaluation tool

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
53
Developing Software
  • Allow sufficient time to correct 508 deficiencies
    and still meet the schedule for production
  • Remember the Contracting Officer is the only
    person who can authorize changes to a contract
  • Contractor is responsible for ensuring compliance
    until the Government accepts the system

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
54
Developing Software
  • All software task orders should have a section
    that requires the product to be 508 compliant
  • Depending on the type of contract, a contractor
    is responsible for correcting any deficiency at
    their cost

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
55
USPTO Process Initial Steps
  • Define requirements - They drive the development
    of the system
  • SDM (Software Development Manager) signs the
    checklist certifying that the system will be 508
    compliant
  • Coordinator reviews the system and initials the
    checklist

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
56
Initial Steps
  • Checklist becomes part of the requirement
    documentation
  • Developer determines the applicable standards
  • Developer provides the applicable standards to
    testing organization
  • There should be testing criteria for each
    standard and that is what the testers use for
    determining compliance

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
57
Initial Steps
  • Developer provides the applicable standards to
    testing organization
  • There should be testing criteria for each
    standard and that is what the testers use for
    determining compliance

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
58
Web Development
  • Most visible 508 areaboth internally and with
    customers
  • The more complex and fancy a site, the more
    difficult it may be to make compliant
  • This does not imply that you have to dummy down
    the site

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
59
Web Development
  • Web products must comply not only with Section
    508, but also any other standards and formats
    prescribed by the agencys webmaster
  • No matter what the requirements are to post a web
    document, Section 508 has priority since it is a
    law

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
60
Web Development
  • Several tools exist for web evaluations, although
    differing tools sometimes yield differing results
  • Do not rely on the tools as the final determining
    factor for compliance
  • Always use at least two different evaluation
    tools, one of which should be the tool that the
    Webmaster uses

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
61
Web Development Tool Examples
  • Wave 4.0
  • http//wave.webaim.org/
  • Web Developer toolbar for Mozilla Firefox
  • https//addons.mozilla.org/en-US/firefox/addon/60
  • HiSoftware
  • http//www.hisoftware.com/

62
Training
  • Critical area since many requirements for
    promotion and skills are based on IT training
    media. People get testy when they miss out on
    promotions
  • Secondary issue is training site that must
    support assistive technologies

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
63
Training
  • Frequent training problems
  • PowerPoint slides
  • Problems when Informative Animations, Images, and
    Diagrams are used without text equivalents
  • Use the Notes section to provide information
  • Interactivity - Providing a text version of the
    training is not the same as interactivity

Section 508 ? USPTO Process ? Hardware and COTS ?
Micro-Purchase ? Software ? Web ?Training
64
State policies regarding adoption of Section 508
  • Several states have also adopted policies
    modeled after Section 508 regarding
  • Accessibility of web sites,
  • Application development,
  • And IT procurement

http//accessibility.gtri.gatech.edu/sitid/stateLa
wAtGlance.php February, 2006
65
States adopting Section 508
  • Alabama Maine Oregon
  • Arizona Maryland Pennsylvania
  • Arkansas Massachusetts Rhode Island
  • California Michigan South Carolina
  • Colorado Minnesota South Dakota
  • Connecticut Mississippi Tennessee
  • Delaware Missouri Texas
  • Florida Montana Utah
  • Georgia Nebraska Vermont
  • Hawaii Nevada Virginia
  • Idaho New Hampshire Washington
  • Illinois New Mexico Washington, DC
  • Indiana New York West Virginia
  • Iowa North Carolina Wisconsin
  • Kentucky North Dakota Wyoming
  • Louisiana Oklahoma
  •  

66
Section 508 Refresh is on the Way!
  • Current Section 508 standards published December
    2000
  • 2008 - Advisory Committee created to review and
    update Section 508 standards and
    Telecommunication Act guidelines
  • First update since 2000 of standards and
    guidelines
  • Advisory committee presented report of
    recommendations to the US Access Board on April
    3, 2008

67
Section 508 Refresh is on the Way!
  • Eight subcommittees were created by the Access
    Board
  • General interface requirements and functional
    performance criteria
  • Software, Web, and Content
  • Telecommunications
  • Audio/Video
  • Self contained, closed products
  • Desktops, portables, peripherals, and other
    computer hardware
  • Section 508 Subpart A (Purpose, Application,
    General Exceptions, Definitions, Equivalent
    Facilitation)
  • Documentation and technical support
  • Information about the refresh can be found at
  • http//www.access-board.gov/sec508/update-index.ht
    m

68
Further resources
  • More information on Section 508 can be
  • found at
  • http//www.section508.gov
  • http//www.access-board.gov/508.htm
  • http//www.buyaccessible.gov/

69
Section 508 government programs
  • Several examples of Section 508 programs at
  • http//www.uspto.gov/web/offices/cio/s508/
  • http//www.section508.va.gov/
  • http//www.ssa.gov/oag/acq/oagacq_508.htm

70
Thank you
  • Contact Information for Section 508 and the Buy
    Accessible Wizard (BAW)
  • Terry Weaver, Director terry.weaver_at_gsa.gov
  • Helen Chamberlain, Section 508 Program Director
    helen.chamberlain_at_gsa.gov
  • Bill Hetzner, BAW Team bill.hetzner_at_newvectors.net
  • Jim Kindrick, BAW Team jim.kindrick_at_newvectors.net
  • Mike Stebbins, BAW Program Manager
  • Mike.stebbins_at_aticorp.org
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