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[email protected] | www.ssbbartgroup.com | (800) 889-9659

Section 508 Refresh: Understanding the New Requirements

Jonathan AvilaChief Accessibility Officer


Section 508 Basics

[email protected] | (800) 889-9659 | www.ssbbartgroup.com

Overview

• Requires Electronic and Information Technology (EIT) developed, purchased, used, and maintained by the Federal government to be accessible to people with disabilities

• The United States Access Board issues the standards• Required for all US Federal government ICT

– Adopted as a best practice for procurement by most US public sector organizations

– Often required for state programs using Federal funds (Section 504)


Covered Technology

“Includes information technology and any equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to: • Telecommunications products (such as

telephones),• Information kiosks and transaction machines,• World Wide Web sites,• Multimedia, and • Office equipment such as copiers and fax

machines.”

Quoted from § 1194.4 Definitions of the Section 508 regulations


Regulatory Status


Timing

• NPRM published in Federal Register February 27th, 2015• 90 day comment period completed May 28th, 2015

– 135 comments received on NPRM (Regulations.gov)– Initial regulations had around 100 comments– 384 written comments on 2010 ANPRM– 91 written comments on 2011 ANPRM– Two ANPRMs looked like a good Access Board strategy

• Comments will need to be addressed and incorporated into the final rule

• Rule approved by OMB• Rule approved by Board


Timing Limitations - Application

• Once final rule is published, application generally trails • Likely effective 182 days after publication in FR• Complaints can be filled under 508 rules six months after

rules take effect • Conformance may vary - no central enforcement or policing

Each federal department/agency must revise their procurement policies and directives

• Matches 6 month complaint window and gives you an “effective date” of six months after publication in the FR


Projected Calendar

Milestone Period DateNPRM draft to OIRA for economic impact assessment DONE 3/31/2014

OIRA completes NPRM review DONE 6/29/2014

OIRA review notes incorporated into draft NPRM DONE 2/17/2015

NPRM published in Federal Register DONE 2/27/2015

NPRM comment period DONE 5/28/2015

NPRM incorporation of comments 395 Days 6/26/2016OIRA completes final regulation review 90 Days 9/24/2016

OIRA review notes incorporated into draft NPRM 15 Days 10/9/2016

Rule approved by Board Varies 11/8/2016

Final rule published in Federal Register 5 Days 11/13/2016

Rule effective date 60 Days 1/12/2017

Complaints allowed under new rules 182 Days 5/14/2017

FAR and procurement policy updates due 182 Days 5/14/2017


The Refresh


General Themes

• Use consensus based standards when possible (WCAG 2.0, PDF/UA)– Normalize to WCAG 2.0 as base standard for web, electronic

content and software– Harmonize with other international standards and regulations

• Focus on functional use profile v. product type• Define coverage for electronic content• Clarify scope of functional performance criteria• Define AT interoperability requirements• Define requirements of authoring tools• Generally bring the standard up-to-date with the modern era


Standards Structure

• Overall– Scoping requirements– Functional performance criteria– Technical requirements– Technical requirements organized around types of technology

versus product types• Requirements of all relevant technology apply

– For example, a mobile phone contains hardware, software and content all in one product

– Overlap of product requirements a point of much confusion in the current standards

– Validate a system based on all relevant technical requirements• Clarify the set of standards that will apply to a system


Harmonization and Standards

• Focus on voluntary international consensus standards for core technical requirements– Idea – Bigger accessibility market = better, more accessible solutions– Idea – One global accessibility standard

• Harmonize with other web and electronic content standards (Australia, New Zealand, Canada, Japan, Germany, France)

• Harmonize with international standards such as the European Union’s EN 301-549 standard for public procurement of ICT

• Ten referenced standards• Only really need to care about the Web Content Accessibility Guidelines

(WCAG) 2.0– A and AA success criteria– Conformance requirements

• PDF/UA-1 can be used for PDF docs

http://www.etsi.org/deliver/etsi_en/301500_301599/301549/01.00.02_30/en_301549v010002v.pdf


Functional Performance Requirements

• Functional performance requirements only apply in situations where: – A technology standard/guideline does not exist to address the

situation – As an equivalent manner to meet the standards when a technique

standard cannot be met• Theoretically a safe harbor for products that are technically

compliant but not usable by people with disabilities– Practically unlikely to be the case

• In practice should make things much easier to validate• Remaining functional performance criteria tweaked for clarity• No cognitive requirement


Electronic Documents

• Arguably covered under the current standards but interpretations vary

• All public facing content covered• Internal “official agency business”

covered• Content is broadly defined –

includes agency websites, blog posts, social media sites, e-mails and the like

• Official content posted on non-agency URL seems to be covered


Electronic Documents (cont.)

• Official business content includes the following: – An emergency notification;– An initial or final decision adjudicating an administrative claim

or proceeding;– An internal or external program or policy announcement;– A notice of benefits, program eligibility, employment

opportunity, or personnel action;– A formal acknowledgement or receipt;– A questionnaire or survey;– A template or form; or – Educational or training materials.

• Narrow archival exception – can’t be publicly available


Electronic Documents – Technical Standards

• WCAG 2.0 A and AA • PDF/UA-1 as a backup• Authoring tools also covered• A system that can generate covered

content needs to support the generation of accessible content


Interoperability Requirements

• ICT must be interoperable or compatible with documented features of assistive technology and accessibility features

• Applies to software – Not applicable to web apps – WCAG 2.0 safe harbor– Would apply to mobile apps– Would apply to mobile hybrid apps

• General focus: use operating system APIs and standard system accessibility functions when available– Avoid re-implementing the drop down – use the OS native

dropdown• Use the SELECT element not some funky div thing you created• Avoid creating editable keyboard focusable DIV elements use

TEXTAREA instead


Documentation and Support

• Product supporting documentation - notably product documentation - must now clearly conform to WCAG 2.0 A & AA requirements

• Provide alternative formats for individuals that are blind or low vision on request

• Provide overview of accessibility features


Other Notes

• Real-time Text (RTT) support required as equivalent to two-way synchronous text communication (e.g. VOIP)


Applying WCAGWhat does conformance mean

• Conform to the A and AA success criteria• Conform to the WCAG Conformance Requirements

– Allows alternative versions of content can be used to meet the standards

– Define an objective way to determine whether techniques meet the WCAG success criteria

– Require systems be usable by assistive technology in a given environment to conform

– Accessibility Supported– Non-interference– Don’t actually have to make a formal WCAG conformance claim

http://www.w3.org/TR/UNDERSTANDING-WCAG20/conformance.html


Questions?


Thank You

Contact Jonathan AvilaChief Accessibility [email protected]

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Intelligence

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• Fifty-five thousand audits (55,930)

• One hundred fifty million accessibility violations (152,351,725)

• Three hundred sixty-six thousand human validated accessibility violations (366,096)

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