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Revised Section 508 Key Things You Need to Know!

Revised Section 508 Key Things You Need to Know!. Bruce Bailey IT Accessibility Specialist U.S. Access Board John Slatin AccessU St. Edward’s University, JBWS 366 May 16, 2016, Austin, TX. Agenda. Today’s presentation assumes people are generally comfortable with the “508 Requirements”

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Revised Section 508 Key Things You Need to Know!

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  1. Revised Section 508Key Things You Need to Know! Bruce BaileyIT Accessibility SpecialistU.S. Access Board John SlatinAccessUSt. Edward’s University, JBWS 366May 16, 2016, Austin, TX

  2. Agenda Today’s presentation assumes people are generally comfortable with the “508 Requirements” • What is different? • What is new with the Revised 508 Standards? • How does WCAG impacts 508? • What are the frequently asked questions the Access Board gets?

  3. Please See Our 508 Webinars! The Access Board has a 508-oriented webinar every other month • www.accessibilityonline.org/cioc-508 In 2017, we the focus was on the Revised Standards: • Final Standards and Guidelines (1/31/2017) • WCAG 2.0 and the Revised Section 508 (3/28/2017) • Old versus New (5/30/2017) • 508 Chapter 4 Hardware (7/25/2017) • 508 Chapter 5 Software (9/26/2017) • Open Question and Answer (4/30/2019)

  4. Architectural and Transportation Barriers Compliance Board (1973) Independent Micro-Agency (30 staff) • 25 Board Members • 13 Public Presidential Appointees • 12 Senior Federal Agencies Representatives We develop and maintain design criteria (ABA, ADA, 508, 255) • Built Environment • Transit Vehicles • Information and Communication Technology (ICT)

  5. ICT Final Rule – Background Combined rulemaking under two separate statutory authorities: • Rehabilitation Act – Section 508 (29 USC § 794d(a)(3)) • Communication Act – Section 255 (47 USC § 255(e)) Revised existing regulations: • 36 CFR Part 1193 (Section 255) • 36 CFR Part 1194 (Section 508) This presentation focuses only on 508

  6. Dates for the Revised Section 508 Standards • Publication Date in the Federal Register: January 18, 2017 • Effective Date: March 21, 2017 • Compliance Date: January 18, 2018 • Correction to the Final Rule: January 22, 2018

  7. The final rule is comprised of both the Revised 508 Standards and the Revised 255 Guidelines In the CFR, they appear as Appendices to 36 CFR part 1194 Final Rule Structure and Organization • App. C: • FPC & TechnicalCh. 3, 4, 5, 6, 7 7

  8. Information and Communication Technology Standards and Guidelines: 36 CFR Part 1194 Appendix A 508 Chapter 1: Application and Administration 508 Chapter 2: Scoping Appendix B 255 Chapter 1: Application and Administration 255 Chapter 2: Scoping Appendix C Chapter 3: Functional Performance Criteria Chapter 4: Hardware Chapter 5: Software Chapter 6: Support Documentation and Services Chapter 7: Referenced Standards Appendix D EIT Accessibility Standards as Originally Published on December 21, 2000 8

  9. Section 508 Statue (the law) • Section 508 of the Rehabilitation Act of 1973, as amended • 29 USC § 794(d) Electronic and information technology • Access Board to develop standards • GSA to provide technical assistance • Agencies to implement Standards (the requirements) • 36 CFR Part 1194 • Technical standards and Functional Performance Criteria (FPC) • Access Board develops and promulgates • Agencies implement

  10. Broad Application of WCAG 2.0 WCAG 2.0 Level A and AA Success Criteria and Conformance Requirements applied to: • Web content (e.g. online instructional materials) • Covered non-Web documents (e.g. training materials) • Software user interfaces (e.g. Learning Management System) • Documentation and Support (e.g. LMS help docs)

  11. WCAG 2.0 Incorporation By Reference (IBR)

  12. WCAG 2.0 Incorporation By Reference Citations to WCAG 2.0: • 508 Chapter 2 • E205.4 Accessibility Standard (under E205 Electronic Content) • E207.2 WCAG Conformance (under E207 Software) • Chapter 5: Software • 504 Authoring Tools • Chapter 6: Support Documentation and Services • 602.3 Electronic Support Documentation

  13. WCAG 2.0 IBR for Electronic Content E205.4 Accessibility Standard Electronic content shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0 (incorporated by reference, see 702.10.1) • Exception for non-Web documents from the four Success Criteria that are for “sets of Web pages” • E205.4.1 details the word substitution needed to apply WCAG 2.0 to non-Web documents

  14. WCAG 2.0 IBR for Software E207.2 WCAG Conformance User interface components, as well as the content of platforms and applications, shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0 (incorporated by reference, see 702.10.1) • Exception, word substitution, and rewrite of WCAG Conformance Requirement 3 • Same approach as with E205.4 • But for software instead of documents • Mechanics of word substitution more complex • Exception for software that is assistive technology

  15. Delineation of Covered Electronic Content (Revised 508 Standards only) E205.2 Public Facing • Electronic content that is public facing shall conform… E205.3 Agency Official Communication • Content that is not public facing • Agency official communication in nine categories • Exception for NARA records

  16. E205.3 Agency Official Communication • 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 of receipt • A survey questionnaire • A template or form • Educational or training materials • Intranet content designed as a Web page

  17. Covered content: Are PDFs covered by 508? It depends! Look to E205 Electronic Content • All content is required to be accessible when either: • Public Facing (E205.2) • e.g., posted on the web or otherwise shared with the general public • Agency Official Communication (E205.3) • PDFs might be used in one of the covered categories (A-I) If content in PDF format meets E205.2 or E205.3, then it’s covered!

  18. What about other file types? What about Microsoft Word or PowerPoint or Excel? • Same analysis as with PDF • If content meets E205.2 or E205.3, then it is covered! What about file formats that don’t support accessibility? • Examples: native files for AutoCAD and Photoshop • Can content be converted to a different file type which is accessible? • For public posting, the content might be converted to PDF or HTML • If business needs require a specific file type that does not support accessibility, then exception for Fundamental Alteration (E202.6) may apply

  19. New “Safe Harbor” Provision in the revised 508 Standards (E202.2) Any component or portion of existing ICT that complies with an earlier standard issued pursuant to Section 508 of the Rehabilitation Act of 1973 (as amended), and that has not been altered on or after January 18, 2018, shall not be required to be modified to conform to the Revised 508 Standards. “Existing ICT” and “Alteration” are defined in E103.4

  20. E202 General Exceptions (cont.) E202.7 Best Meets. Where ICT conforming to one or more requirements in the Revised 508 Standards is not commercially available, the agency shall procure the ICT that best meets the Revised 508 Standards consistent with the agency’s business needs. • E202.7.1 Required Documentation • E202.7.2 Alternative Means

  21. E202.7 Best Meets E202.7.1 Required Documentation The responsible agency official shall document in writing: • the non-availability of conforming ICT, including a description of market research performed and which provisions cannot be met, and • the basis for determining that the ICT to be procured best meets the requirements in the Revised 508 Standards consistent with the agency’s business needs.

  22. E202.7 Best Meets E202.7.2 Alternative Means Where ICT that fully conforms to the Revised 508 Standards is not commercially available, the agency shall provide individuals with disabilities access to and use of information and data by an alternative means that meets identified needs.

  23. Functional Performance Criteria (FPC)- Changes to Technical Requirements FPC added to address cognitive accessibility (302.9) • New to Revised 508 Standards • Already in original 255 Guidelines • Harmonizes with EN 301 549 (European Union standard) FPC for Limited Hearing (302.5) and Limited Vision (302.2) modified • Responsive to NPRM comments • More closely harmonize with EN 301 549 standard

  24. Role of the FPC Clarified FPC Used Only When: • Technical requirements in Chapter 4 (Hardware) or Chapter 5 (Software) do not address ICT function • Assessing claim of equivalent facilitation

  25. Does a federal agencyhave to comply with Section 508? • Yes! • Section 508 (of the Rehabilitation Act) only applies to Executive Branch Federal Agencies • The Access Board’s Revised 508 Standards impose mandatory accessibility requirements only on Federal entities • Applies to Federal contracts, but up to agencies to enforce • Some Federal grant or other funding programs makes compliance with 508 Standards a condition of program participation

  26. Use of the 508 Standardsoutside federal government • Many non-federal websites are required to be accessible under other laws, such as the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act of 1973, or state or local laws • To achieve ICT accessibility, some non-federal entities incorporate, adopt, or reference the 508 Standards • The Access Board does not make this determination • Please consult your authoritative source for specific program information or requirements • Funding source • Relevant statutes • State or federal agency

  27. Can an agency claim that ICT is 508 conformant by merely providing an accommodation? • No! • Providing human assistance or special alternate technology for a user to access ICT is a reasonable accommodation (Section 504 of the Rehabilitation Act) • The ICT does not become conformant with Section 508 by providing an accommodation • The agency must claimanException (such as Best Meets, Undue Burden or Fundamental Alteration) in order to comply with 508 and to use the ICT • After claiming the exception, an “Alternative Means” may be required to provide access to information and data

  28. What is Alternative Means? • Alternative Means are part of the Exceptions for Best Meets, Undue Burden, and Fundamental Alteration • Excerpt from E202.6.3 (emphasis added): • the agency shall provide individuals with disabilities access to and use of information and data by an alternative means that meets identified needs • 508 compliance includes exceptions • Maybe the ICT (that the agency is procuring) does not fully conform to 508 requirements found in Chapters 4 and 5 • The agency can still be 508 compliant because they are following an exception

  29. Can an agency use an accommodation as Equivalent Facilitation? • No! • These are two different concepts • Equivalent Facilitation is not an accommodation • Equivalent Facilitation is asserted when there are novel approaches that provide greater accessibility and usability than would be provided by fully conforming to 508 requirements found in Chapters 4 and 5

  30. When do I use WCAG?When do I use Chapter 5? • Is there a lot of overlap between WCAG and Chapter 5? • Yes, but there are no conflicts or contradictions • Does software on the web follow Chapter 5 requirements or WCAG? • Software on the web should use WCAG 2.0 Level AA • WCAG was developed for robust interactive web applications as well as static HTML pages

  31. What is “Web Software” anyway? • Revised 508 Standards include definitions for: • Software • Non-Web Software • Web page • Should “web software” follow Chapter 5 requirements or WCAG? • Use WCAG for: • Software running in or launched by your web browser • Use Chapter 5 for MS Windows and Apple OS applications • Software might require an Internet connection, but it’s still not a “Web page”

  32. Do Section 508 and WCAG 2.0 apply to apps?What about mobile? • Yes! • “Apps” or applications are software (mobile and desktop) • Software is defined at E103.4 • Also see E207: • Where components of ICT are software and transmit information or have a user interface, they shall conform to the requirements in Chapter 5 Software and conform to WCAG 2.0 Level A and AA Success Criteria and Conformance Requirements

  33. What do I do about maps and Geographical Information Systems (GIS)? • Software needs to follow WCAG 2.0 Level AA • Maps are hard to make fully accessible! • Conveying a useful textual equivalent of robust visual information is not something we know how to do. Do the best you can! • The general requirement from SC 1.1.1 is that there be a “text alternative that serves the equivalent purpose” • However, SC 1.1.1 also allows providing only descriptive identification for non-text content that is “primarily intended to create a specific sensory experience” • Other accessibility requirements (e.g., navigation via the keyboard) are applicable

  34. Would a web application ever have to meet more requirements than are in WCAG? • If the web application plays videos • 503.4 (User Controls for Captions and Audio Description) applies • WCAG already requires captioning and audio description • It would unusual for there not to be an option to turn on/off CC/AD • If the web application lets you create content • 504 (Authoring Tools) applies • Chapter 6, Support Documentation and Services, is probably applicable

  35. Does 508 require WCAG 2.1? • No! The Revised 508 Standards cite to WCAG 2.0 only • Incorporation by reference is to a specific dated version (Dec. 11, 2008) • This will not change without a formal rulemaking process • WCAG 2.1 adds requirements to WCAG 2.0 • 2.1 adds accessibility requirements specific to mobile and touch UI • If a website conforms to WCAG 2.1 Level AA, it will conform to WCAG 2.0 Level AA • Conformance with WCAG 2.1 is optional and not required for 508

  36. Training from Access Board • The Access Board can provide training on the standards and guidelines that we promulgate • To request training from us, visit www.access-board.gov/training • Access Board’s Section 508 Best Practices Webinar Series • See schedule and archives • www.accessibilityonline.org/cioc-508

  37. Where else can I get 508 training? • W3C Introduction to Web Accessibility • www.w3.org/WAI/fundamentals/accessibility-intro • WCAG 2 Quick Reference • www.w3.org/WAI/WCAG20/quickref • GSA’s Section508.gov Training • www.Section508.gov/training

  38. Is there an “official 508 Certification”? • There is no official Section 508 certification or license for a person • DHS Trusted Tester – ACOP supported test methodology • https://www.section508.gov/test/trusted-tester • Online training and exam certification • DHS Accessibility Help Desk: accessibility@hq.dhs.gov

  39. Is there a 508 stamp or icon? • There is no official 508 symbol to indicate conformance of a product

  40. Documenting 508 Conformance — VPATS • VPAT is an Information Technology Industry Council initiative • www.itic.org/policy/accessibility • Q: What to do with VPATs that cite original Section 508 Standards (2000)? • A: Those VPATs are outdated and not usable • Current VPATs reference Revised 508 Standards

  41. Questions?

  42. Resources

  43. W3C Robust Technical Assistance: Web Accessibility Initiative homepage: w3.org/wai W3C Resources: • Web Content Accessibility Guidelines 2.0: w3.org/tr/wcag20 • Understanding WCAG 2.0: w3.org/tr/understanding-wcag20 • Techniques and Failures for WCAG 2.0: w3.org/tr/wcag20-techs • Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies (WCAG2ICT): w3.org/tr/wcag2ict

  44. W3C WCAG Quick Reference The “How To Meet WCAG2.0” document, aka Quick Reference • w3.org/wai/wcag20/quickref • Actually a database: • Customizable • Searchable The Quick Ref is day-to-day resource designed for routine use by developers for developers • The Quick Ref is the most practical way to browse the full the Techniques and Failures

  45. Resources www.Access-Board.gov • Section 508 Standards and Section 255 Guidelines, including technical assistance • ICT Final rule (2017) • Regulatory Impact Analysis • Overview and Press Release • More guidance material under development

  46. Resources www.adaconferences.org/CIOC/Archives • Archives of Section 508 “Best Practices” Webinar series (2013-2017) • Sponsored by the U.S. Access Board and CIO Council (CIOC) • New program every other monthly www.Section508.gov • GSA website with 508 technical assistance • FAQs • Best Practices • Including how to make documents accessible • Word, PDF, Excel, and more in progress

  47. U.S. Access Board (800) 872-2253 (voice), (800) 993-2822 (TTY) 508@access-board.gov, www.access-board.gov

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