Section 508 to be updated

Section 508 is being updated. I participate on the Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) which has been working on recommended language for the last year or so. We are getting closer to finalized language and hope to make our recommendations to the U.S. Access Board in January. Because Section 508 and the Telecommunication Act, which we’re also updating, have such far reaching impact on accessibility, we invite you to review the draft provisions and send us feedback.

A few things to note:

  • Section 508 is much more than web standards. These provisions apply to all electronic and information technology, including telephone systems, copiers, computer monitors, etc. While the existing guidelines focus on individual technologies (there are distinct sections for HTML, software, applets, etc.), the language TEITAC will recommend puts all of the guidelines in one place, but focuses more on product characteristics (e.g., “If the product has speech output…”).
  • Section 508, in the strictest sense, applies only to U.S. federal agencies. The practical implications are much broader, but the language of the provisions is targeted to procurement of goods and services by agencies. The guidelines are not intended to be comprehensive, formal design guidelines, such as WCAG 2.0. However, you’ll notice that the draft 508 standards are identical to WCAG 2.0 in many places.
  • The provisions are in draft form. Once finalized, these provisions will only be recommendations. As such, they can and will be changed. It will take at least two years of editing, clarification, public comment, and statutory review before these standards will be finalized.

You can review the most recent draft of the provisions at http://teitac.org/wiki/EWG:Draft_Oct_26. You will likely be very overwhelmed by this document. Much of it deals with the statutory implementation of Section 508. Much of the document is committee notes and documentation. If you are interested in reviewing the technical provisions that apply to web content, please read the following sections:

There are other provisions that would affect web accessibility, but gleaning them from this complicated document may be a bit difficult. You may also want to review the definitions, as much of the meat of the provisions is contained there.

There is not a formalized method for providing feedback to TEITAC. But, as a member organization, if you give us your feedback in the comments below or by contacting us directly, we’ll review your feedback and pass it on.

Comments

  1. Dennis from Web Axe

    Thanks for the post, Jared. Good to know Section 508 is being updated, and that your helping! Yes, many people don’t realize that only a small portion of Section 508 has to do with *web* accessibility…

  2. Patrick

    As I quickly scanned the draft document, I had a question about the “Large Scale Text” in Section 1194.4 Definitions. It says “At least 18 point or 14 point bold”. Then there are two notes, with the second one being “Note 2: Font size is the size when the content is delivered. It does not include resizing that may be done by a user.”

    Does this mean that web pages need to be delivered at 18 point font minimum?

    I’m sure that I missed something since that’s a huge font size.

  3. Nancy

    This is a great article however I only scanned section 3.

    I had a basic question under 3-b. How would we determine what is a 3:1 or 5:1 contrast?

    Also what does 3-w mean
    3-W – Multiple Ways (New provision)

    More than one way is available to locate content within a set of Web pages where content is not the result of, or a step in, a process.

  4. Patty O'Sullivan

    Hi, thanks for sharing “Section 508 to be Updated” – this REALLY NEEDS to go beyond “federal agencies” and needs to include private and public industries. Having it written with “practical implication is much broader” is not going to be all that helpful.

  5. Patrick

    Nancy,

    As for meeting the contrast requirement in 3-B, you could try one of the tools available here:
    http://www.w3.org/WAI/ER/tools/complete.php

    Note that I haven’t tried any of the tools yet for a color contrast reading. I would be interested to know if any of the tools scan a web page as a whole and lets you know of the problem areas.

  6. Jared Smith

    I’ll attempt a few answers:

    Patrick-
    The provisions state that text must have a contrast ratio of 5:1, but large scale text (at least 18 point or 14 point bold) can have a lower contrast ratio (3:1). It needs less contrast if it’s bigger.

    Nancy-
    The formula for determining contrast ratio is in the “Contrast Ratio” definition. But to understand that, you need to look at the “Relative Luminance” definition, which provides a rather complex formula. Luckily, as Patrick noted, there are a few tools out there that can do all of the work for you for web content.

    I’m not sure about the “Multiple Ways” provision. That one must’ve snuck in there at the last minute. here’s details on how it works in WCAG 2.0. It is intended to require multiple mechanisms for locating each web page on a site. I’m not convinced this is always a good idea, particularly for simple sites. I’ll seek more info.

    Patty-
    Section 508 itself has a fairly limited scope. This does not limit others from using the guidelines in other arenas (state laws, corporate policies, best practices, etc.). However, some modifications would be needed to make them applicable in non-government areas.

  7. Liz L

    There is a great tool that I use to test contrast in colors: http://www.hp.com/hpinfo/abouthp/accessibility/webaccessibility/color_tool.html

  8. Liz L

    Do you know if the existing checkpoints for Section 508 Standards for Electronic
    and Information Technology 1194.21, 1194.22, 1194.31 and 1194.41 will have verbiage
    removed, modified or added? Will there be new checkpoints? Will checkpoints be
    removed or merged? Will this effect Voluntary Product Accessibility Templates
    (VPATs)? If the subparts and checkpoints are modified a crosswalk to identify
    changes would be greatly appreciated.

  9. Jared Smith

    Do you know if the existing checkpoints… 1194.21, 1194.22, 1194.31 and 1194.41 will have verbiage removed, modified or added?

    First, we are only making recommendations. What ultimately is changed has yet to be determined. If the recommendations we will make are applied, it will result in fairly significant modifications to these provisions.

    Will there be new checkpoints? Will checkpoints be removed or merged?

    Yes. We’ve tried hard to not go backward, but there are a few provisions that were dated or that are combined into a more comprehensive provision. There will almost certainly be many new checkpoints.

    Will this effect Voluntary Product Accessibility Templates
    (VPATs)?

    Yes, because the provisions themselves will change. Also, instead of there being distinct software, web, plugins, etc. provisions, our recommendations will likely focus on technology and technology characteristics in general. This will likely make a VPAT-like process more difficult, but will (hopefully) result in vendors and agencies taking a broader and more comprehensive look at accessibility.

    If the subparts and checkpoints are modified a crosswalk to identify changes would be greatly appreciated.

    I believe that documentation on changes will be part of the subcommittee product. But in short, our recommendations would change almost everything.

  10. Liz L

    Thank you kindly for your feedback Jared. Is there a mailing list I can join
    to stay on top of the recommendations related to Section 508 Standards for
    Electronic and Information Technology 1194.21, 1194.22, 1194.31 and 1194.41?

  11. Jared Smith

    Liz-

    There really isn’t a mailist list. You can follow the activity on the wiki (http://teitac.org/wiki) or read the archives of the private committee mailing list at http://teitac.org/mailarchives/archives.php?id=1

  12. Jan

    Looking at the current Section 508 1194.22(o) “A method shall be provided that permits users to skip repetitive navigation.” Where is a similar provision in the updated standards?

    I understand that by using semantic markup, a screen reader can jump from heading to heading, in affect skipping repetitive navigation. How about the keyboard user? How would they be accommodated if the original requirement is not stated anywhere? (This is assuming that skip to content links might not be provided anymore because it doesn’t appear to be a requirement any longer.)

    Thanks!

  13. Jan

    3-K Consistent Identification says –
    Components that have the same functionality within a product must be identified consistently.

    Then impact is designated as significant with one point being “Cost to remediate existing applications could be very high.”

    Does this mean that existing applications must comply with the updated Section 508?

    I know management will want to know, for sure, what this means.

    Again, THANKS!

  14. Jared Smith

    Jan-

    Regarding ‘skip navigation’ links. This in not directly required in the current draft. You are required, however, to provide sufficient headings and document structure. But you are right, this is not the same as a required ‘skip navigation’ link.

    A few reasons why it is currently not there:
    - The requirements must be testable. It is hard to really determine what “repetitive navigation” is.
    - We are striving for harmonization with other guidelines. This requirement is not found in other guidelines. WCAG 2.0 (draft) does require a mechanism for skipping repeated blocks across pages. This could mean a skip navigation link, but it also allows page structure and headings to be sufficient.
    - Requiring “skip navigation” links does not really allow for other mechanisms that may be better in the future. Navigating with the keyboard by headers or page structure is good – we simply need tools and browsers to do this (the User Agent Accessibility Guidelines have required this since 2002, yet very few tools provide this option for keyboard users). HTML 5, ARIA, and several other upcoming technology specifications allow you to specifically define in your page what the navigation is and what the content is. Tools could easily provide keyboard access to these without the need for an invasive link. We wouldn’t want to require “skip nav” links in the future when MUCH better mechanisms for doing the same thing are on their way.

  15. Jared Smith

    Jan-

    Regarding “Consistent Identification”…

    I agree that this is a problematic requirement. It is there primarily to harmonize with WCAG 2.0. You can read more about WCAG’s mechanisms for meeting this requirement.

    Does this mean that existing applications must comply with the updated Section 508?

    The changes to Section 508 will apply to procurements made after the changes are implemented. This means that old products will only need to be retrofitted if they will be part of a new product or service procurement. You will have no obligation to fix products that were purchased previous to the new requirements being enacted.

  16. Jan

    Thanks Jared! I appreciate your help!

    I have one question about this statement you made -

    “The changes to Section 508 will apply to procurements made after the changes are implemented. This means that old products will only need to be retrofitted if they will be part of a new product or service procurement. You will have no obligation to fix products that were purchased previous to the new requirements being enacted.”

    I assume “procurements” include “applications developed in-house or software/hardware purchases from a vendor.” Is that correct? So we are under no obligation to retrofit current web applications.

    Thanks, JAN

  17. Murat

    A few reasons why it is currently not there:
    - The requirements must be testable. It is hard to really determine what “repetitive navigation” is.
    - We are striving for harmonization with other guidelines. This requirement is not found in other guidelines. WCAG 2.0 (draft) does require a mechanism for skipping repeated blocks across pages. This could mean a skip navigation link, but it also allows page structure and headings to be sufficient.

  18. Forum Keyif.com- Keyfini çıkarın

    thanks

    A few reasons why it is currently not there:
    - The requirements must be testable. It is hard to really determine what “repetitive navigation” is.
    - We are striving for harmonization with other guidelines. This requirement is not found in other guidelines. WCAG 2.0 (draft) does require a mechanism for skipping repeated blocks across pages. This could mean a skip navigation link, but it also allows page structure and headings to be sufficient.