# Presentation: 128076

## Section 508BFederal IT Accessibility InitiativeSummary

**NASA and GRC Implementation Status **

## Workforce Investment Act of 1998 - Section 508B Requirements

- When Federal Agencies develop, procure, maintain, or use Electronic Information Technology, Federal employees with disabilities must have access to and use of information and data that is comparable to the access and use of information and data by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency.

## Workforce Investment Act of 1998 - Section 508B Requirements

- Individuals with disabilities, who are members of the public seeking information or services from a Federal agency, must have access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities, unless an undue burden would be imposed on the agency.

## Undue Burden

- 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
- The term "undue burden," is based on case law interpreting Section 504 (Southeastern Community College v. Davis, 442 U.S. 397 (1979))

## Applicability

- Electronic Information Technology (EIT)
- Telecommunications products, information kiosks, WWW sites, multimedia, office equipment (FAX, copiers), and of course most manner of computers, ancillary equipment, software, firmware, services and related resources.
- Information
- Any information that is captured, used, re-used, disseminated, stored or otherwise processed by EIT is covered.
- If agency claims undue burden to provide electronically, then information must be provided by an alternative means.
- To the public if information is for the public
- To employees if information is required for their job

## Remedies

- Section 508 authorizes persons with disabilities to file administrative complaints with agencies or to file lawsuits in federal court on or after June 21, 2001.  Lawsuit enforcement provisions only apply to procurements made in violation of section 508.  Administrative procedures must be patterned after those established for resolving other allegations of discrimination.
- For information on the network, if it is not available in a standards compliant form, then it must be made available in an alternative (accessible) form at no added charge.

## Six Subsections of Technical Specifications

- 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

## Software Standards 1 of 2

- (a) Keyboard Access - no mouse needed
- (b) OS Accessibility Features - no overrides
- (c) Current Focus - cursor, selection
- (d) Interface Elements - controls, menus
- (e) Images - consistent meaning
- (f) Text - OS protocols
- (g) User Defined Attributes - text size

## Software Standards 2 of 2

- (h) Animation -  textual equivalent
- (i) Color - no dependencies
- (j) Color Contrast - effective e.g. not black on blue
- (k) Screen Flicker - not between 2 and 55 Hz
- (l) Electronic Forms - able to complete & submit
- Layout  i.e. logical organization when read
- Hierarchy  i.e. logical grouping
- Response time  i.e. warning and  adjustable timeout

## Industry Situation

- Congress’ intent is to use government acquisitions to drive the marketplace (similar to Energy Star, Closed-captioned TV, ...)
- General agreement that EIT vendors will self-certify compliance on web pages and product literature, using a simple and easy to understand template.
- Vendor self-certification information beginning to appear.  Until heavily populated, procurement requestors will be significantly burdened.

## Deadlines

- Center plan for overall compliance in place by September 30, 2001.
- Draft plan developed and approved.
- Information newly made available over the network after June 21, 2001 must be accessible or undue burden  be documented.
- Agency-level undue burden argument already made to extend compliance dates for Web information.
- Guidance being addressed by CSD Web Team.
- All acquisitions must be compliant by June 25, 2001 unless undue burden documented.
- Acquisition processes developed, training and awareness sessions in process, implementation has begun.

## GRC Status - Web Information

- Overall plan is organizationally focused review of all web pages and renovation as appropriate over next 2 1/2 years.
- GRC “Top 20” web pages to be compliant by September 30, 2001.
- As of September 30, 19 of top 20 fully compliant.
- CSD Web Team has provided training sessions and voluminous information on their web site.

## GRC Status - Acquisition Policy and Process

- Only compliant products are to be acquired (where possible, based on market survey) after June 25, 2001.
- Requirements/timelines specifications, and evaluation of product compliance against standards are the  responsibility of the requestor.
- Office of Acquisition/CSD Team has developed acquisition documentation, review processes, templates, and guidance documentation.
- Implementation now in process.

## Information Source

- http://www.grc.nasa.gov/WWW/Purchase/Section_508_Site.htm
- Or
- From the Web Intranet @ Glenn home page, enter 508 into the Transporter and follow your nose.

## Teams

- Web
- Mary Ann Bents
- Jimmy Gonzalez
- Kathy Naugle
- Laurie Yost
- Pat McElroy
- Karen Edwards
- Kelly Heidman
- Grisselle Lafontaine

- Acquisition
- Robin Strohacker
- Karen Edwards
- Rita Poulsen
- Erline Trsek
- Bob Firestone
- Mildred Bergman
- Paivi Tripp

## Backup Material

## Web Remediation Schedule

## Acquisition Processes

- Accessibility standards will, to a large extent, be considered during the _*planning and requirement*_* *_*development stages*_ of an EIT acquisition.
- For some EIT acquisitions, accessibility standards will be considered during the _*solicitation and evaluation stages*_ of the procurement.
- We must comply with those accessibility standards that can be met with supplies or services that are available in the commercial marketplace in time to meet our delivery requirements.

## Web Accessibility Check List

- Alternative Text for Images, Animation, and Multimedia
- Use of Color and Contrast
- Style Sheets
- Data Tables
- Identify Frames
- Flickering Content

- Scripts, Applets and Plug-ins
- Forms
- Skip Repetitive Links
- Timed Response
- Text Only Equivalents
- Descriptive Links

## Synopsis of Standards(some details)

## Technical Standards (Subpart B)

- The standards provide criteria specific to various types of technologies, including:
- software applications and operating systems
- web-based information or applications
- telecommunication products
- video and multimedia products
- self contained, closed products (e.g., information kiosks, calculators, and fax machines)
- desktop and portable computers
- (see http://www.section508.gov/final_text.html)

## Software Applications and Operating Systems (1194.21)

- Most of the specifications for software pertain to usability for people with vision impairments.
- Alternative keyboard navigation, which is essential for people with vision impairments who cannot rely on pointing devices, such as a mouse.
- Other provisions address animated displays, color and contrast settings, flash rate, and electronic forms, among others.

## Web-based Intranet and Internet Information and Applications (1194.22)

- Ensure access for people with vision impairments who rely on various assistive products to access computer-based information,
- Screen readers, which translate what's on a computer screen into automated audible output, and refreshable Braille displays.
- Conventions, such as verbal tags or identification of graphics and format devices, like frames, are necessary so that these devices can "read" them for the user in a sensible way.

## Web-based Intranet and Internet Information and Applications (1194.22)

- Use of text labels or descriptors for graphics and certain format elements. (HTML  code already provides an "Alt Text" tag for graphics which can serve as a verbal descriptor for graphics).
- Also addresses the usability of multimedia presentations, image maps, style sheets, scripting languages, applets and plug-ins, and electronic forms.

## Telecommunications Products (1194.23)

- Designed primarily to ensure access to people who are  deaf or hard of hearing.
- Compatibility with hearing aids, cochlear implants, assistive listening devices, and TTYs (devices that enable people with hearing or speech impairments to communicate over the telephone)
- One requirement calls for a standard non-acoustic TTY connection point for telecommunication products that allow voice communication but that do provide functionality.
- Other specifications address adjustable volume controls for output, product interface with hearing technologies, and the usability of keys and controls by people who may have impaired vision or limited dexterity or motor control.

## Video or Multimedia Products (1194.24)

- Multimedia products involve more than one media and include, but are not limited to, video programs, narrated slide production, and computer generated presentations.
- Caption decoder circuitry (for any system with a screen larger than 13 inches) and secondary audio channels for television tuners, including tuner cards for use in computers.
- Captioning and audio description for certain training and informational multimedia productions developed or procured by Federal agencies.
- Standards also provide that viewers be able to turn captioning or video description features on or off.

## Self Contained, Closed Products (1194.25)

- This section covers products that generally have imbedded software but are often designed in such a way that a user cannot easily attach or install assistive technology.
- Examples include information kiosks, information transaction machines, copiers, printers, calculators, fax machines, and similar types of products.
- Require that access features be built into the system so users do not have to attach an assistive device to it.
- Other specifications address mechanisms for private listening (handset or a standard headphone jack), touchscreens, auditory output and adjustable volume controls, and location of controls in accessible reach ranges.

## Desktop and Portable Computers (1194.26)

- This section focuses on keyboards and other mechanically operated controls, touch screens, use of biometric form of identification, and ports and connectors.

## Functional Performance Criteria (Subpart C)

- The performance requirements of this section are intended for overall product evaluation and for technologies or components for which there is no specific requirement under the technical standards in Subpart B.
- Designed to ensure that the individual accessible components work together to create an accessible product.
- They cover operation, including input and control functions, operation of mechanical mechanisms, and access to visual and audible information.

## Functional Performance Criteria (Subpart C)

- The performance requirements of this section are intended for overall product evaluation and for technologies or components for which there is no specific requirement under the technical standards in Subpart B.
- Provisions are structured to allow people with sensory or physical disabilities to locate, identify, and operate input, control and mechanical functions and to access the information provided, including text, static or dynamic images, icons, labels, sounds or incidental operating cues.

## Information, Documentation, and Support (Subpart D)

- The standards also address access to all information, documentation, and support provided to end users (e.g., Federal employees) of covered technologies.
- Includes user guides, installation guides for end-user installable devices, and customer support and technical support communications.
- Information must be available in alternate formats upon request at no additional charge. Alternate formats or methods of communication, can include Braille, cassette recordings, large print, electronic text, Internet postings, TTY access, and captioning and audio description for video materials.