# Presentation: 196089

## Section 508 for Software Managers and Developers 

**Larry G. Hull**
**June 10, 2004**

## Agenda

- Section 508 Introduction
- Software Accessibility
- Keyboard Exercise
- Technical Specifications
- Functional Criteria
- Documentation, Training, and Support
- Assistive Technology
- Resources

## What is Section 508?

## Section 508

- Federal agencies' electronic and information technology is to be accessible to people with disabilities
- Employees
- Members of the public
- Workforce Investment Act of 1998 contained two significant additions
- Enforcement
- Technical standards

## Enforcement

- Individuals with disabilities can file a complaint concerning the inaccessibility of an agency's electronic or information technology
- Alternatively, individuals may file a civil action against an agency
- Remedy is agency compliance, i.e., not a monetary penalty or reward

## Department of Justice

- Section 508 Home Page
- _[http://www.usdoj.gov/crt/508/508home.html](http://www.usdoj.gov/crt/508/508home.html)_
- Self-Evaluation Surveys
- Every two years, Section 508 requires the Department of Justice to report to the Congress and the President on the federal government's progress in complying with section 508
- No Enforcement Role

## Architectural and Transportation Barriers Compliance Board

- Independent Federal Agency
- Created in 1973
- Primary mission is accessibility for people with disabilities
- Directed to publish Federal E&IT technical standards
- Draft issued March 20, 2000
- Final issued December 21, 2000
- Standards effective June 25, 2001
- Exempts only national security systems

## Six Subsections

***Software applications and operating systems***
- Web-based intranet and internet information and applications
- Telecommunications products
- Video and multimedia products
- Self contained, closed products
- Desktop and portable computers

## Contractor Obligations

- Contractors are not required to procure accessible hardware and software to carry out government related activities, unless contract calls for delivery
- If the contract calls for delivery, the hardware and software must be accessible, more specifically must comply with Section 508

## Agency Obligations

- Federal agencies must comply with the standards when  it develops, procures, maintains or uses electronic and information technology
- Federal agencies must comply with these standards unless to do so would be an ***undue burden*** and undue burden must be documented

## Undue Burden

- The term "undue burden" is based on case law interpreting Section 504 (Southeastern Community College v. Davis, 442 U.S. 397 (1979))
- The term "undue burden" is also used in Title III of the Americans with Disabilities Act. (ADA), and is analogous to the term "undue hardship" in Title I of the ADA

## Undue Hardship

- Congress defined the term as “an action requiring significant difficulty or expense”
- Agency resources available to a program or component are considered in determining whether an action is an undue burden
- Case-by-case basis
- Other (unspecified) factors may be considered, e.g., an accessible product does not (yet) exist

## Undue Hardship (continued)

- Section 508 requires agencies to procure (develop) accessible electronic and information technology regardless of whether they have employees with disabilities
- Eliminates any need for later retrofitting
- Retrofitting is changing /adding requirements and may be a significant difficulty or expense
- Agencies prohibited from procuring (developing) inaccessible E&IT then claiming hardship

## Equivalent Facilitation

- Designs or technologies that result in substantially equivalent or greater access to and use of a product for people with disabilities
- Not a waver or a variance
- Future technologies or existing technologies used in new ways may provide the same functional outcome -- e.g., voice recognition/activation replaces a keyboard

## NASA & Section 508 Software Compliance

- NASA among Section 508 leaders in procurement and web sites
- Training and guidance exist and more is in the works
- Web compliance V&V is coming this summer (at GSFC)
- NASA’s draft software policy document, NPR 7150.x, (new numbering) requires Section 508 compliance
- Software Engineering Requirement # 14 [SWE014] is
-     The project shall ensure that software is accessible to individuals with disabilities as required by Section 508 of the Rehabilitation Act (29 U.S.C. 749d), as amended.  Specific requirements for accessibility may be found at 36 CFR Part 1194, available at
-     _[http://www.access-board.gov/sec508/508standards.htm](http://www.access-board.gov/sec508/508standards.htm)__ _
- Training and guidance do not yet exist
- Compliance V&V is likewise non-existent

## Software Accessibility (Section 508 Goal)

## Accessibility - My View

-  	What does “software accessibility” mean?
-  	To me, it means that anyone should be able to use any electronic and information technology and have the full and complete ability to interact with the software whether or not the person has a disability.
-     Applies not only to E&IT interfaces, but also to **documentation, training, and support**.

## Information Technology

- Any equipment or interconnected system or subsystem of equipment used in automatic acquisition, storage, manipulation, control, movement, management, display, switching transmission, or reception of information
- computers and ancillary equipment
- software, firmware and similar procedures
- services (including support services)

## Accessibility and Compliance

- The term accessible was defined in the proposed Section 508 rule as compliance with the rule’s technical standards
- Comments received objected to using this definition of accessibility as a measure of compliance (circular)
- Final Section 508 rule does not define or use the term “accessible”

## Disable Yourself

-  **Exercise in Keyboard Navigation**

## Keyboard Navigation

- Bring up the Windows Internet Explorer browser
- Turn off images, sound, multimedia, Java, JavaScript, ActiveX, etc.
- Tools > Internet Options > Advanced (tab) > Multimedia and uncheck all boxes
- Optional: Tool > Security > Custom Level and disable
- Run ActiveX controls and plug-ins
- Active scripting
- Navigate a favorite web site or two or three_x0008_

## Keyboard Navigation - Continued

- KEYBOARD ONLY   i.e., forget the mouse
- Hints:
-        the “tab” key is your friend
-        alt & left arrow replaces the back button
-        alt & F4 closes a window
-    (Don’t forget to restore check boxes and enable optional controls if disabled)
- Example:  _[http://www.section508.gov](http://www.section508.gov/)__ _

## Software Technical Standards

## Software Applications and Operating Systems

- Section 1194.21 (a) through (l) address software applications and operating systems
- Ensures _access_ for people with disabilities who rely on assistive products
- Not universal accessibility (accessibility for all)
- Not necessarily usability either (another issue/topic)

## Keyboard Access (a)

- When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually
- Provide a means of invoking commands from a keyboard
- Allow user to tab rather than require a mouse

## Keyboard Access (continued)

- Does NOT require adding a keyboard to a product that is not intended to have one
- Applies to products that are intended to be run on a system with a keyboard
- Requires that only actions that can be discerned textually be executed from a keyboard, e.g., menu functions such as Open, Save, and Close

## Accessibility Features (b)

- Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where features are developed and documented according to industry standards
- Reference to standardized access features was added to proposed rule after receiving several comments that developers can’t be aware of all features in all products

## Features (continued)

- Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer
- Example: Microsoft Active Accessibility (MSAA)
- Application programming elements that provide reliable methods for exposing information about user interface elements such as toolbars, menus, text, graphics, columns, and cells

## Features (continued)

- Software must not affect the usability of other applications or the operating system for people with disabilities
- Examples of accessibility features
- Modifying the color scheme
- Showing a visual prompt for an audio tone
- Providing sticky keys (sequential combinations)
- Control-C
- <Control><C>

## Current Focus (c)

- A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes
- The focus shall be programmatically exposed so that assistive technology can track focus and focus changes
- Focus is where an action will take place
- Tab key is used to move focus

## Interface Elements (d)

- Sufficient information about a user interface element including the identity, operation and state of the element shall be available to assistive technology
- When an image represents a program element, the information conveyed by the image must also be available in text

## Interface Elements (continued)

- Information about program’s controls must be made available to assistive technology, such as screen reading software
- Examples of controls:
- Checkboxes
- Menus
- Toolbars

## Images (e)

- When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application's performance
- Many screen readers allow the user to associate text names with images (icons)
- Changing an image’s meaning renders the text name invalid and is confusing
- Applies only to controls, status indicators, or other programmatic elements

## Text (f)

- Textual information shall be provided through operating system functions for displaying text
- The minimum text information that shall be made available is
- Content
- Attributes
- Input (caret) location

## Text (continued)

- Software for assistive technology is unlikely to be able to interpret unique methods for writing text or displaying graphics on the screen
- Unique methods are not forbidden
- Text must however be consistently written using standard operating system protocols so other software programs can process the output.

## User Defined Attributes (g)

- Applications shall not override user selected contrast and color selections and other individual display attributes
- Many operating systems provide system-wide settings as an accessibility feature
- Personalized settings may include
- Color contrast
- Keyboard repeat rate
- Keyboard sensitivity settings

## Animation (h) 

- When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user
- Animation can pose serious problems for assistive technology such as screen readers
- Animated text (scrolling) can be a problem for people with any of several visual and cognitive disabilities

## Color (i)

- Color coding shall not be used as the _*only*__ _means of conveying information, indicating an action, prompting a response, or distinguishing a visual element
- Example: green start button
- A statement may read "press the green button labeled start to begin"
- The word "start" shall be associated with this green button on the page
- Visually
- As text

## Predict Legibility for Color Deficient Viewers

- Color Vision Simulator
- _[http://www.vischeck.com/showme.shtml](http://www.vischeck.com/showme.shtml)__ _
- Color Deficient Vision
- _[http://www.visibone.com/colorblind/](http://www.visibone.com/colorblind/)__ _
- Safe Web colors for color-deficient vision
- _[http://innovate.bt.com/people/rigdence/colours/](http://innovate.bt.com/people/rigdence/colours/)__ _

## Color Contrast (j)

- When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided
- An overly bright background may cause a visual “white-out” in some users
- User must be able to select a softer background and appropriate foreground colors

## Effective Color Contrast

- Designing for People with Partial Sight and Color Deficiencies
-     _[http://www.lighthouse.org/color_contrast.htm](http://www.lighthouse.org/color_contrast.htm)__ _
- Color Contrast Verification Tool (W3C algorithm)
-     _[http://h10014.www1.hp.com/accessibility/color_tool.html](http://h10014.www1.hp.com/accessibility/color_tool.html)__ _

## Screen Flicker (k)

- Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz
- Rate can induce a seizure in people with photosensitive epilepsy
- Consistent with revised ADA Accessibility Guidelines
- Demonstration
-      http://ncam.wgbh.org/richmedia/media/flicker_demo_start.html

## Electronic Forms (l)

- When electronic forms are used, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues
- The 1998 Government Paperwork Elimination Act requires that Federal agencies make electronic versions of their forms available on-line when practicable
- At present, interactions between form controls and screen readers can be unpredictable
- Developers place control labels in various locations in various distances from the controls themselves
- Screen reader responses are often less than accurate

## What is a Form?

- Form has at least one input field: text box, button, menu or checkbox
- Ordered Q&A pairs
- Form sets the question
- User sets the answer
- If the form has a fill-in blank where the user can't figure out what the question is, the form isn’t usable

## Form Examples

## Grouping Menu Selections

- Long lists of menu selections may be confusing, i.e., difficult to track
- Group items defined into a hierarchy
- Specify a label for the group of options
- Should be a natural grouping
- Yes, this is usability -- usability and accessibility often overlap

## Form Response Time

- When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required or be allowed to turn the timing off
- Disability can have a direct impact on user’s speed
- Very frustrating when form just disappears

## Functional Criteria

## Overview

- Section 508 (a)(2)(A)(ii) required the Board to develop the technical and functional performance criteria necessary for implementation _not design requirements_
- Performance criteria felt to give discretion in achieving the required end result
- Design requirements felt to inhibit development and innovation

## Functional Performance Criteria 

- Ensures that the individual accessible components work together to create an accessible product
- Requires a product’s operation and information retrieval functions must be operable through the six modes addressed

## Product Evaluation

- Software developers and procurement officials need not be aware of the universe of assistive technology products on the market
- Functional provisions specify the _type_ of assistive technology that must be supported

## Vision

- At least one mode of operation and information retrieval that does not require user vision shall be provided
- Support for assistive technology used by people who are blind or visually impaired shall be provided
- Screen readers, e.g., JAWS, WindowEyes

## Visual Acuity

- At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently
- Support for assistive technology used by people who are visually impaired shall be provided
- Screen magnifiers, e.g. ZoomText

## Hearing

- At least one mode of operation and information retrieval that does not require user hearing shall be provided
- Support for assistive technology used by people who are deaf or hard of hearing shall be provided
- Visual notification of alarms (not necessarily separate technology)

## Enhanced Auditory

- Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion
- Support for assistive hearing devices shall be provided
- Audio output for amplifiers, etc.

## Speech

- At least one mode of operation and information retrieval that does not require user speech shall be provided
- Support for assistive technology used by people with speech disabilities shall be provided
- Alternative for voice recognition, etc.

## Motor Control

- At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided
- No support clause for this disability type because of the numerous individual disabilities
**Spinal cord injury**
**Loss or damage of limb(s)**
**Cerebral palsy**
**Muscular dystrophy**
**Multiple sclerosis**
**Spina bifida**
**ALS (Lou Gehrig's Disease)**
**Arthritis**
**Parkinson's**
**Essential Tremor**

## Documentation, Training, and Product Support

## Fully Usable Product

- In order for a product to be fully usable by persons with disabilities, information about the product, training, and product support services must also be usable by persons with disabilities

## Documentation

- Upon request, agency must ensure end-user documentation is available in alternate formats
- Does not require alternate formats of documentation that is not provided by the agency to other users of the technology
- Does require agency supply end-users with information about a product’s built-in accessibility or compatibility features

## Alternate Formats

- Alternate formats usable by people with disabilities include, but are not limited to
- Braille
- ASCII text
- Large print
- Recorded audio
- Other electronic formats

## Alternate Methods

- Different means may be used to provide product documentation and information to people with disabilities including
- Voice
- Fax
- Relay service
- TTY or TDD (telecommunication display device)
- Internet
- Web

## Adobe PDF - Documentation

- Adobe PDF information and resources
-     http://access.adobe.com/information.html
- Adobe instructions for producing an accessible PDF document
- 	http://access.adobe.com/booklet1.html
- NASA Section 508 training has links to creating accessible Acrobat documents
- http://section508.nasa.gov/internal/nasaTraining.htm

## Training

- All training and informational video and multimedia productions, regardless of format, shall be accessible to people with disabilities
- Speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned
- Visual information necessary for comprehension of the content, shall be audio described

## Product Support

- Help desks and other support services serving an agency must be capable of accommodating the communications needs of persons with disabilities
- For example, an agency help desk may need to communicate through a TTY
- Support services must also be familiar with such features as keyboard access and other options important to people with disabilities

## Cost to End-User

- Agencies shall ensure that any information,  documentation, training, or support provided by the agency to end-users is available at no additional charge

## Assistive Technology

## Types of Assistive Technology

- Screen readers
- Screen magnifiers
- Adaptive keyboards
- Word prediction software
- Voice recognition software
- Single switches

## Screen Readers

- Uses
- Text-to-speech software gets information using operating system standard protocols
- Users
- Blind
- Low vision
- Certain cognitive problems

## Refreshable Braille Display

- Uses
- Display driver gets information using operating system standard protocols
- Users
- Deaf-blind (Helen Keller)
- Blind who can't adjust to readers
- Blind who use in addition to a screen reader

## Screen Magnifiers

- Uses
- Enlarges the screen image many times
- Tracks the cursor or active region of the screen
- Users
- Low vision
- Cognitive disabilities
- Potential problems
- Applications that provide a custom cursor may be impossible to view
- Bit mapped images become pixelated and blurry

## Adaptive Keyboards

- Uses
- Standard methods of reading input
- Users: physical / motor disabilities
- Smaller for users with little range of motion
- Larger for users without fine motor control
- Fewer choices for users who benefit from structured choices
- Designed for one hand

## Word Prediction Software

- Uses
- Speeds up typing
- Presents likely word choices
- Often used with adaptive keyboards
- Users
- Physical disabilities
- Cognitive disabilities i.e., difficulty with spelling or vocabulary
- Real-time captioning

## Voice Recognition Software

- Uses
- Input data
- Control the computer
- Users
- Difficulty typing
- Prefer dictation
- Accuracy
- Improving 95% -> 98%

## Single Switches

- Uses: assistive technology / computers
- Control the computer with one or two specific movements
- Scan through options on the screen
- Trigger switch when the option is highlighted
- Users
- Some, often extreme, physical disabilities, e.g., Stephen Hawkins

## Major Assistive Technologies

- JAWS for Windows, generally considered to be the leading screen reader in the US
- _[http://www.freedomscientific.com/index.html](http://www.freedomscientific.com/index.html)_
- Window-Eyes for Windows, major competitor with large number of users
- _[http://www.gwmicro.com](http://www.gwmicro.com/)_
- IBM's Home Page, a speech-enabled browser
- _[http://www-3.ibm.com/able/hpr.html](http://www-3.ibm.com/able/hpr.html)__ _
- ZoomText Xtra, a screen magnifier with speech
- _[http://www.aisquared.com](http://www.aisquared.com/)_

## Assistive Technology Resources

- Designing a More Usable World
- _[http://trace.wisc.edu/world/](http://trace.wisc.edu/world/)_
- Accessibility Technology Center
- http://www.doi.gov/atc/
- The Adaptive Technology Resource Centre
- _[http://www.infocommons.utoronto.ca/atrc/](http://www.infocommons.utoronto.ca/atrc/)_
- EASI's Hardware and Software Vendors
- _[http://www.rit.edu/~easi/resource.htm](http://www.rit.edu/~easi/resource.htm)__ _

## Screen Reader

- “Introduction to the Screen Reader” with Neal Ewers, a short video demonstrating how screen readers assist the blind to navigate the web
-     http://wiscinfo.doit.wisc.edu/ltde/access/ewers.htm
- Video in QuickTime Format
-      http://www.doit.wisc.edu/accessibility/video/intro_scrn_rdrs.mov

## Interface Design Guidelines & Resources

## IBM  & HP Accessibility

- IBM Checklist - key aspects of inclusive design and information about implementation and testing
- 	_[http://www-3.ibm.com/able/accesssoftware.html](http://www-3.ibm.com/able/accesssoftware.html)_
- HP Accessibility Solutions
- 	http://www.hp.com/hpinfo/community/accessibility/index.htm

## Sun Accessibility

- Accessibility Home Page
- 	_[http://www.sun.com/access/](http://www.sun.com/access/)_
- Developer Accessibility Information
- 	_[http://www.sun.com/access/developers/](http://www.sun.com/access/developers/)_
- Accessibility Quick Reference Guide
- 	http://www.sun.com/access/developers/access.quick.ref.html

## Microsoft Product Development

- Microsoft's developer network (known as MSDN) now has a Web area dedicated to helping developers produce technology for people with accessibility needs         http://msdn.microsoft.com/at/
- Microsoft Accessibility Update
- Free e-mail newsletter sent the first week of each month
- http://www.microsoft.com/enable/news/subscribe/

## Apple Accessibility

- Accessibility
- 	http://www.apple.com/accessibility/
- Accessibility Documentation
-  	**http://developer.apple.com/documentation/Accessibility/Accessibility.html**

## Linux Accessibility

- Linux Accessibility HOWTO
- http://tldp.org/HOWTO/Accessibility-HOWTO/
- Blind + Linux = BLINUX
- http://leb.net/blinux/
- Gnome Accessibility Project
- http://developer.gnome.org/projects/gap/

## Trace Research & Development Center

- Useable Design
- http://www.trace.wisc.edu/world/
- Computers and Software
- http://www.trace.wisc.edu/world/computer_access/
- Section 508 Discussion List
- sec508@trace.wisc.edu

## Discussion List Examples

- Does anyone know of a screen reader that will work with UNIX systems?
- Absolutely. It's called Speakup. Many blind folks use it with Linux on I386 and Alpha systems. It also works on Sparc/Solaris.
- 	http://www.linux-speakup.org
- There is an issue of removing extraneous output from CLIs such as dashes (---) so the screen reader won't waste time parsing or translating them. Does anyone know of any information on how a command line interfaces CLI works with screenreaders?
- You can have the screen reader filter out those characters that cause problems, e.g. "-", etc.  All of the screen readers support dictionary options that will allow this to occur.

## Section 508 Web Site

- GSA sponsored government Web site
-        http://www.section508.gov
- Buy Accessible
- Accessible product information from vendors
- About 508
- Statutory and regulatory information
- 508 and You
- Guidance and tools to help implement Section 508
- 508 Training (separate sub-section -- registration is free)
- IRS Section 508 training for software developers
- Resources and Links

## Summary

- Accessibility is a “Good Thing”
- Often improves software usability
- Need not be expensive, but there are exceptions
- Accessibility is the “Right Thing”
- Compliance with Section 508
- Is not “Accessibility”, but
- Is the Law (for Federal Agencies)