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From: indamockwood-l
Date: Fri, Jun 09 2006 8:10AM
Subject: Intepretation on section 508 and use of logic tests
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Dear all,

I am very new to this list, so please forgive me if this is not an appropriate topic. Forgive me too, if this is a little bit long.

I am fairly familiar with the rules regarding section 508 in the United States. And when I (and I think many others) think of accessibility and section 508, I think, in general, of creating web sites that will work well for visual and hearing impaired users.

But is it possible that other disabilities can apply?

The reason I ask, is that recently some members of the US Congress, in order to prevent en-masse postings their web forms, allowed for the introduction of a logic test (go to http://www.house.gov/writerep , select California, and use the zip 93292). Obviously, they are trying to model what other web sites do, where they create a java-produced image on the fly with the funky backgrounds with numbers and make you type those in. However, we all know those are not compliant. So instead we have these text-based logic tests.

My question is this - are these logic tests 508 compliant? I realize that anyone who has a visual or hearing impairment might not have a problem with this, but what about someone with dyslexia or dyscalculia. They may come to these logic tests, not be able to answer the questions, and then be denied access to a web site that an otherwise non-impaired person would have access to.

Am I stretching this a bit? I would just like to get other people's opinions and/or interpretations.

Marissa

From: Austin, Darrel
Date: Fri, Jun 09 2006 8:30AM
Subject: RE: Intepretation on section 508 and use of logic tests
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> My question is this - are these logic tests 508 compliant? I
> realize that anyone who has a visual or hearing impairment
> might not have a problem with this

>From a general opinion standpoint, ANY captcha is a potential
accessibility issue (and/or usability issue as well).

Even for perfectly abled, full-sighted, intelligent, english-reading,
adult people, a captcha can be very annoying/hard to decipher.

IMHO, the better solution (from an accessibility standpoint) to prevent
bot-posting is to use email confirmation systems on the back end. Have
people post, tell them an email has sent that they must reply to, and in
that email just have a link back to the site passing a variable that
will 'confirm' that the person is human.

In the case of this site, they're just using this to prevent spam. If
they are getting Spam through their contact form, then they have a
really poorly written contact form. The whole point of a contact form is
to avoid getting spam.

On the other hand, they MAY be getting hit with malicious mass emails
being sent through the form, which, again, can likely be better handled
server side rather than client side.

As for what accessibility/508 should cover, in my opinion (and this is
one that several people on this list will disagree with me on)
accessibility isn't about any specific disability at all. It's about
making a web site more accessible to more people and more devices. The
term 'universal access' is perhaps more appropriate. Once specific
disabilities are brought up, it seems to pigeonhole people's thinking
and, inevitably, other disabilies are then forgotten.

-Darrel

From: Robinson, Norman B - Washington, DC
Date: Mon, Jun 12 2006 8:50AM
Subject: RE: Intepretation on section 508 and use of logic tests
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Marissa,

The law is very specific. There are no "other disabilities" that
can apply. The technical standards relate basically to the functional
requirements
(http://www.access-board.gov/sec508/standards.htm#Subpart_c) which do
not include any references to mental abilities or anything relevant to
your post that I could see applied to logic tests.

For benefit of the group, the next step when you enter in your
state and zip and ask to contact the representative is:


Unfortunately, with the advent of email communication, some
organizations have begun to use automated programs to send messages to
Congress on behalf of constituents - better known as "SPAM." To prevent
this practice we ask that you answer the question below. When you enter
the correct response it ensures that the message is coming from a real
person and helps your Representative respond to you as quickly as
possible.

What is the sum of eight plus 1? [data entry field] (Submit
button)

You will be allowed up to 3 attempts to provide a correct
response. Failure to provide a correct response will require you to
start over.

If you are unable to provide a correct response but still wish
to contact your Representative, please call his office at 202-225-2523.


So yes, they are compliant, specifically to your questions there
are no technical or functional requirements for mental abilities. That
might be addressed in a future version of revisions to Section 508, but
that isn't the case today.

I'd say you are stretching. Why bother to see what laws apply
and what technical requirements apply if you don't like the form. I
think their approach is the wrong approach. If you are affected you need
to demand they give you something usable, that they use your funding
appropriately and solve the technical issues with SPAM filtering without
frustrating the user. That has nothing to do with the law and everything
to do with your right to insist they do the right thing. Also, playing
devils advocate, you mention the potential problem but are you aware of
adequate solutions? Mental ability and technical standards that might
address them are more difficult to create than some of the other
approaches for the other senses. It can be done, but I don't want
someone suggesting that because of dyslexia I'm going to need to
transpose multiple interpretations of my phone contact number. I think
this gets more into usability and universal design issues that I would
welcome being addressed in the law but don't expect a direct answer to
your questions to follow.

Focus on the positive and plan for how things fail.

Best of luck,


Norman

From: Sandra Clark
Date: Mon, Jun 12 2006 9:00AM
Subject: RE: Intepretation on section 508 and use of logic tests
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I'd also like to point out that neither Congress nor the Judicial Branch
actually are required to follow Section 508. The only ones who are are the
Federal Agencies and those receiving funding from those Agencies. (The
White House is also not required to follow 508).

>From section508.gov
"In 1998, Congress amended the Rehabilitation Act to require Federal
agencies to make their electronic and information technology accessible to
people with disabilities. Inaccessible technology interferes with an
individual's ability to obtain and use information quickly and easily.
Section 508 was enacted to eliminate barriers in information technology, to
make available new opportunities for people with disabilities, and to
encourage development of technologies that will help achieve these goals.
The law applies to all Federal agencies when they develop, procure,
maintain, or use electronic and information technology."


Sandra Clark
=============================http://www.shayna.com
Training in Cascading Style Sheets and Accessibility

From: Jared Smith
Date: Mon, Jun 12 2006 7:50PM
Subject: Re: Intepretation on section 508 and use of logic tests
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Robinson, Norman B - Washington, DC wrote:
> So yes, they are compliant, specifically to your questions there
> are no technical or functional requirements for mental abilities. That
> might be addressed in a future version of revisions to Section 508, but
> that isn't the case today.

The process for revising the guidelines for electronic and information
technology will begin shortly. These guidelines will likely be used to
update Section 508 of the Rehabilitation Act and the Telecommunications Act.

While the process for updating the guidelines and standards will begin
shortly, the legislative process for implementing them into either Act may
be some time off. There are certainly weaknesses in the Section 508
standards, but those weaknesses are recognized and will hopefully be
rectified.

Jared Smith
WebAIM.org

From: Robinson, Norman B - Washington, DC
Date: Mon, Jun 26 2006 11:00AM
Subject: RE: Intepretation on section 508 and use of logic tests
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Sandra,

I'd like to point out the law specifically names the United
States Postal Service. The Access Board is the official government
agency responsible for the provisions and technical standards for
Section 508. You can view the final standards via URL
http://www.access-board.gov/508.htm.

Also, the Access Board's standards describe the tests for
compliance. The USPS AS-508-A Section 508 Technical Reference Guide
describes in more detail how to achieve compliance: AS-508-A, Section
508 Technical Reference Guide in HTML:
http://www.usps.com/cpim/ftp/hand/as508a/welcome.htm & AS-508-A, Section
508 Technical Reference Guide in PDF Format for printing:
http://www.usps.com/cpim/ftp/hand/as508a.pdf.

Finally, I would like to encourage any reader to update the
Wikipedia page on Section 508: http://en.wikipedia.org/wiki/Section_508.

I hope the links are of use to you.

Regards,


Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service