Section 508 & Accessibility - IDRAC 2014 - Timothy Creagon - US Access Board

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On October 4th 2014 Timothy Creagon presented these materials as part of Virtual Ability's International Disability Rights Affirmation Conference (IDRAC) This presentation discusses the reasoning behind the provisions of Section 508 of the US Rehabilitation Act as well as the barriers and successful methodologies of implementing accessibility features in technology.

Transcript of Section 508 & Accessibility - IDRAC 2014 - Timothy Creagon - US Access Board

Section 508: The Basics

Section 508 and Accessibility

2014 International Disability Rights Affirmation Conference (IDRAC) October 3-4, 2014

Second Life

1Todays speaker: Timothy CreaganSenior Accessibility SpecialistU.S. Access Board


2Todays topics: IntroductionBarriers to Information Technology508 of the Rehabilitation Act Complying with Section 508: Testing and policies Equivalent Facilitation The Refresh of Sections 508 & 255Q & A 3I. Introduction: Access Board ProgramsGuidelines and standards developmentArchitectural Barriers Act of 1968Americans with Disabilities Act of 1990Telecommunications Act of 1996Rehabilitation Act Amendments of 1998Patient Protection and Affordable Care ActTechnical assistance and training ***ResearchABA enforcement4II. Barriers to Information Technology for persons with disabilities


Have you ever struggled to see the characters on a screen?6Seeing:PhonesIlluminated displaysHigh contrast controlsLarge buttonsComputersZoom displayHigh contrast displayScreen reader


7Hearing:PhonesHearing aid compatibilityText capabilityVibrating alertsComputersVideo captionsVisual alerts



Holding and manipulating:Phones:Large buttonsLightweightSpeed dialComputersSticky keysKeyboard commandsVoice recognition



9III. Section 508 of the Rehabilitation Act

Overview10508 General Requirements:Each Federal department and agency, as well as the U.S. Postal Service, when procuring, maintaining, developing or using electronic and information technology, must ensure that:

Federal employees with disabilities, and members of the public with disabilities seeking information or services, have access to and use of information and data that is comparable to the access and use by persons who are not individuals with disabilities, unless

Standard: .an Undue Burden would be imposed on the agency. 11Section 508 Standards focus on product categories of ICT: Software applications and operating systems 1194.21Web-based internet and intranet information and applications 1194.22Telecommunications products 1194.23 Video and Multimedia products 1194.24Self contained, closed products 1194.25Desktop and portable computers 1194.26

12Section 508 also focuses on the USER: *Known as Part C Functional Performance Criteria

1194.31(a) does not require user visionsupport for AT used by blind or visually impaired

1194.31(b) does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print, or support for AT.

1194.31(c) does not require user hearingsupport for AT used by deaf or hard of hearing

1194.31(d) where audio information is important, enhanced audioor support for AT

1194.31(e) does not require user speechsupport AT

1194.31(f) does not require fine motor control or simultaneous actions and is operable /w limited reach13What technology is covered by 508?

Includes, but is not limited to


Kiosks Printers SoftwareOffice Equipment14However, time has passed.and technology has changed.

Today, what a product DOES is more important that what a product is CALLED.

Feature/Function versus Product name

Question:How Can we use Section 508 to evaluate todays technology? 15For example, what features are included in 1194.23 Telecommunications Products ?

2 way voice communicationControls and keysHardwareMinimize Hearing aid interferenceText messaging(TTYs)IVR (Interactive Voice Response, menus) 16Today there are many more products available with many more features : FOR EXAMPLE, Telecommunications Products:

Landline phones, wireless phones, Smart phones: Voice communication

TTYs, SMS, Blackberry, iPhone, Sidekick, Twitter: Text messaging

SKYPE: Calls/ Video Conferencing

Zoomtext or other software: Adjust size of text

Web sites: Contain information about product features

17Section 508 still applies; analyze the features of the technology:

Subpart B Technical Standards - do any apply? E.g. 1194.23, 1194.21, 1194.22

Subpart C Functional Performance Criteria do any apply? E.g. 1194.31(a) (f)

1194.5 Equivalent Facilitation - the new technology or design [not necessarily in Section 508] results in substantially equivalent or greater access to and use of a product for people with disabilities DOES THAT APPLY? E.g. voiceover for Apple iOS

1194.3 General Exceptions: Do any apply? E.g. 1194.3 (e ) Fundamental Alteration 18What about technology that has features not addressed by 508?EXAMPLE:Mobile TelecommunicationsiPods and Podcasting - Operate without buttons Smart Phones with touch screens [Voiceover][Talkback]

19Making technology accessible: CaptionsAlternative formats: text for audio, alt tags for imagesUse of API (Application Programming Interface) to address compatibility between AT and IT software (make products interoperate) Apps or Applications on Smart phones20IV. Complying with Section 508: A. Policies and testing B. Equivalent Facilitation

21Implementing Section 508 Agencies use the Section 508 technical standards and Functional Performance Criteria when they procure, use, maintain or develop Electronic and Information technology (E&IT)Agencies are responsible for developing their own policies as to how they implement Section 508 within their own agencies22Complying with Section 508: Sample policies and testing protocols

23Sample policies and resources: HHS Section 508 web standards and checklists:

VA Section 508 Support: Access Board:

24 Free testing tool bars:

Webaim: WAVE:

Web Accessibility tool bar:

25CIOC Best Practices Webinar seriesSEE:

How Four Federal Agencies Handle Section 508 Testing: A Case Study March 25, 2014

26Complying with Section 508: Equivalent Facilitation

27281194.5 Equivalent FacilitationNothing in this part is intended to prevent the use of designs or technologies as alternatives to those prescribed in this part provided they result in substantially equivalent or greater access to and use of a product for people with disabilities.28Using Equivalent Facilitation to achieve access by alternative means: Use WCAG 2.0 (Web Content Accessibility Guidelines) What is WCAG 2.0? International standard for web documents and web applicationsW3C Standard (2008)ISO Standard (2012): ISO/IEC JTC-1 40500:2012W3C/WAI: World Wide Web Consortium / Web Accessibility InitiativeDeveloped through open and inclusive standards process

2930Why use WCAG 2.0? Technology NeutralUnlike 508 1194.22, not HTML specific

Success Criteria: (aka Requirements)Address existing 508 technical criteria (1194.21 and .22)Address 508 functional performance criteriaHearing, Sight, Manual Dexterity, SpeechPartially address Cognition, Language, and Learning (CLL) Are Objectively TestableWritten to be evaluated as yes/no or true/false statements.3031Is WCAG 2.0 being used now? FEDERAL AGENCIES:Department of Transportation, Non-Discrimination on the Basis of Disability in Air Travel: Accessibility of Web Sites and Automated Kiosks at U.S. Airports, Final rule December 13, 2013Department of Justice, Accessibility of Web Information and Services of State and Local Government Entities and Public Accommodations, ANPRM July 2010 (Proposed)

INTERNATIONALLY:Canada Australia New ZealandEuropean Union (EU) (Mandate 376)3132WCAG 2.0: POUR ConceptThe 4 PrinciplesPerceivableContent is made available to the senses - sight, hearing, and/or touchOperableInterface forms, controls, and navigation are operableUnderstandableContent and interfaces are understandableRobustContent can be used reliably by a wide variety of user agents, including assistive technologies

POURs Overlapping TenetsIllustration of the words Perceivable, Operable, Understandable and Robust wrapping over and under each other.3233How to Meet WCAG 2.0How To Meet WCAG2.0 - daily resource document for the day-to-day Developeris a DatabaseQuick Reference: way to get to the Techniques and Failures3334Concluding thoughts about WCAG 2.0 : The Success Criteria are the RequirementsThe Techniques are not required but provide guidance

WCAG 2.0 can be used Equivalent Facilitation (1194.5)

Built-in Prioritization Path/Plan (for Development/Remediation/QA)

WCAG 2.0 Support Documents are Regularly Updated

3435W3C Resources: Web Content Accessibility Guidelines (WCAG) 2.0: URL:

Understanding WCAG 2.0:Stable URL:

How to Meet WCAG 2.0: URL:

Techniques for WCAG 2.0: Stable URL:

Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT)URL: 35IV. The Refresh of Section 50836The Refresh of Section 508:The Refresh is an update of:

Section 508 standards for electronic and information technology (E&IT) (procured by Federal agencies)

Section 255 guidelines for telecommunications products37Why Refresh? Statutory requirement: The Access Board shall periodically review and, as appropriate, amend the standards to reflect technological advan