# Presentation: 317905

## Slide 1

## Issues Raised During Technical Assistance

**David Baquis, Accessibility Specialist**
**508@access-board.gov**

## General Issues

- What audience are you writing for?  What reading level?  How do you balance plain language with the integrity of technical information?
- Would you suggest adding ‘advisory notes’ to the 508 Standards?  Those would be recommendations, not requirements.  See the advisory appendix of 255.
- Some agencies feel that the current standards primarily address the “office environment” and not other federal work environments.  Solicit input specifically from these other types of federal sites.

## Electronic Information:508 Determinations

- Is electronic content E&IT?
- Was it the intent of the law that the 508 standards would only address ‘technology’ accessibility?
- Are additional standards needed for “information and data”, as distinct from “technology”?
- Problem: Employees unable to do jobs because some electronic media is not accessible, and then they are told that it is not even covered by 508
- Problem: Agencies feel that they can’t ask contractors to make documents accessible because that’s not explicitly stated in the 508 Standards

## Electronic Information:Scope of Coverage

- What kind of information media is covered?
- HTML and multimedia seems clear, but ....
- PDFs - [Is 1194.22(a) appropriate to justify their access?]
- All other documents/formats (spreadsheet, slide shows, word-processed, etc)
- Emails (and their attachments)
- Where can (or must) the information reside?
- Only on a website? or also...
- Off of a website on CDs, thumb drives, internal servers
- Note that multimedia video is covered _regardless of format_

## Scale and Weight

- Agencies/libraries are scanning millions of documents electronically and backing them up on servers
- Do the 508 standards adequately address accessibility of e-documentation?
- Increasing reliance on e-learning for training (distance learning, distributed learning, online collaboration)
- Does 508 adequately address the accessibility of learning management systems and courseware?
- Geographic Information Systems (GIS) and GPS

## How to Use the Standards

- How do I determine which technical requirements apply to a product? (Examples: some of the web requirements are under software; all-in-one office products; components such as external hard drives.)
- Do I use the functional performance criteria if I already designed to specific technical provisions?
- Need examples of equivalent facilitation, for clarity
- Can the concept of “comparable access” stand alone as a standard for product design and evaluation? This has been argued when a system is 508-conformant but someone still feels technological discrimination.

## Is it Covered by 508?

- Scientific and research equipment such as electron microscopes, chromatographs and spectrometers
- Laboratory and medical equipment, such as ultrasound, MRI, and autorefracter/topographer
- Our E&IT definition incorporates Clinger-Cohen definition of IT. We cannot change their definition of IT. Their examples are problematic (e.g., medical equipment and HVAC with embedded IT). People are looking to use that strict definition to sidestep 508.
- This is a big deal since it determines whether a 508 design and evaluation process is kicked-in.

## Conformance Sufficiency

- In product design, how do I know when I have done enough to meet the 508 Standards?
- Ok to be compatible with 1 brand of AT only?
- What and how much should I write in an alt tag?
- What is a sufficient timed response duration?
- Range and types of colors to meet color/contrast provision?
- “I’ve read the requirement, but don’t know what to do.”
- Do you recommend that the Access Board develop advanced technical assistance on creating accessible documents? (or reference other TA?)

## Hearing Enhancement

- Should the standards/guidelines take into account the advantage of ‘network-based amplification’ over ‘telephone-based amplification’?  (You need to understand the difference between ‘receive amplification’ and ‘side tone amplification’.)
- Is there research evidence to justify the newer standard for telephone amplification level of 20 dB? Has more been better?
- Consider examination of other factors (amplitude, frequency, clipping, compression) that might be manipulated to impact clarity.  (This may now be possible with VoIP)
- Consider recommending research in noise cancellation circuitry for telecom headsets (technology transfer from pilot’s headsets).
- Consider recommending research to develop/study other means (besides EMF/telecoils) of achieving interoperability between hearing instruments and communication technology.

## Voice Mail, Auto-attendant, IVR

- See IVR Forum Checklist: Should features such as interrupt, pause, rewind and repeat be reframed as ‘necessary for accessibility’ and included in 255/508? Also, see how these are handled in the VVSG (Voluntary Voting Systems Guidelines).
- Do you really want to require that an IVR system be compatible with TTYs in the ASCII mode?  Consider clarifying what is meant by “non-proprietary TTY code”. And clarify that a TTY user is not a TRS user with respect to this direct-TTY IVR requirement.

## Telecom - Other

- Problem of firewalls and VRS access. How to open a port while minimizing security risk.
- VoIP – What are the barriers?  Illustrate convergence and application of provisions (web, telecom, software). Could the Committee benefit from a presentation on IP-enabled products?
- HAC provisions could reference the 2003 FCC R&O (which combined magnetic coupling and minimized interference )
- Regarding TTY users mentioned in the Caller ID provision: Is it still necessary to segregate TTY users from digital networks?  Have TTY users ever had access to full system functionality when put on separate analog lines?  Wouldn’t procurement of a universally accessible system be a higher standard?
- The provision addressing both VCO toggling and TTY direct connection could be unbundled as two separate issues

## Multimedia

- Problem of combining a new projector with a DVD player, which, as an integrated system, may not display captions. (Frequent complaint from colleges)
- Some handhelds display video captions clearly – Consider revising standards to cover small screens?
- Possible advisory note for real-time audio description?
- Is there a voluntary consensus standard for captioning that can be referenced? (This issue is driven by complaints of poor captioning quality.)

## Documentation/Support (Subpart D)

- Clarify that ‘support’ can mean more than TTY access. Give other examples (e.g., e-mail, IM chat, cell, pager)
- Discuss whether “communication needs” could also mean knowledgeable help desk staff (e.g., familiar with keyboard equivalents)
- Technical product support documentation reliant on visuals may not be usable when converted to readable text if not rewritten to describe technical directions. Should that be reframed as an accessibility issue?

## A Few Exceptions Issues

- Clarify application and scope of national security exception. Find a Clinger-Cohen expert to inform you.
- Clarify the multiple conditions necessary to meet for use of the back office exception. Perhaps use an advisory note.
- Note that some exceptions are not included in the cluster of exceptions under 1194.3.
- Fitness for duty: Medically screened/non-disabled. Not necessarily law enforcement. Not national security exception.
- No such population-specific exception exists right now
- Remember 508 NPRM comments that resulted in reversal of proposed rule on video captioning conditional upon disability assessment of anticipated audience

## Additional Issues

- What to do with the category header of self contained, closed products, given that technology developments have ‘opened up’ many of those products?
- Standards could specify that conformance requires that accessibility features actually be activated (set up TTY messages and timed responses)
- When an adaptor enables an IT product to be AT compatible, specify that it needs to be readily available (not wait 3 weeks while we order it for you)