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Thread: Section 508 Testing/Section 508 Refresh

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Number of posts in this thread: 15 (In chronological order)

From: McDonald, Jennifer
Date: Mon, Jun 06 2011 10:21AM
Subject: Section 508 Testing/Section 508 Refresh
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The company that I work for has been notified that our website and
web-based applications will be tested to determine "how well it complies
with the standards of the Rehabilitation Act of 1973 as amended in
1998". We do work on behalf of the Department of Education. Has anyone
been through this before? While we feel confident that we're indeed
accessible, we're wondering which standards they'll use to test by.
I've been performing all of my analysis based on WCAG 2 - and I've been
researching Section 508 Refresh. Do they use real people to test
objectively? Or do they run it through a validator?

If anyone has had any experience with a government accessibility review
I would love to hear about it.

Thanks,

Jennifer McDonald
Great Lakes Higher Education Corporation
Ecommerce - Assistant Web Producer
Web Design and User Experience



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From: Angela French
Date: Mon, Jun 06 2011 10:30AM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Who did the notifying?

From: Duff Johnson
Date: Mon, Jun 06 2011 10:51AM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Jennifer,

By all means, consider your web-pages... but do not neglect your PDF files!

I've heard several stories about agencies which (chose) to ASSUME the subject of a Section 508 compliance audit would be HTML/CSS/JavaScript... only to discover that the auditors are interested in ALL the content, not just the stuff posted in HTML.

For many government agencies, PDF documents comprise 30% (or more) of the content they place online. In some cases the proportion is closer to 90%.

It's important to review and address inaccessible PDFs because they are a common source of complaints. Accessible PDF is entirely achievable, but it requires systematic attention, just like everything else.

Duff Johnson
Appligent Document Solutions, CEO

US Committee for ISO/DIS 14289 (PDF/UA), Chair

22 E. Baltimore Ave
Lansdowne, PA 19050
+1 610 284 4006
+1 617 553 1934 (direct)
= EMAIL ADDRESS REMOVED =
http://www.appligent.com
http://www.twitter.com/duffjohnson



On Jun 6, 2011, at 12:20 PM, McDonald, Jennifer wrote:

> The company that I work for has been notified that our website and
> web-based applications will be tested to determine "how well it complies
> with the standards of the Rehabilitation Act of 1973 as amended in
> 1998". We do work on behalf of the Department of Education. Has anyone
> been through this before? While we feel confident that we're indeed
> accessible, we're wondering which standards they'll use to test by.
> I've been performing all of my analysis based on WCAG 2 - and I've been
> researching Section 508 Refresh. Do they use real people to test
> objectively? Or do they run it through a validator?
>
> If anyone has had any experience with a government accessibility review
> I would love to hear about it.
>
> Thanks,
>
> Jennifer McDonald
> Great Lakes Higher Education Corporation
> Ecommerce - Assistant Web Producer
> Web Design and User Experience
>
>
>
> --------------------------------------------------------------------------------
> The information contained in this communication may be confidential, is intended
> only for the use of the recipient(s) named above, and may be legally
> privileged. If the reader of this message is not the intended recipient, you
> are hereby notified that any dissemination, distribution, or copying of this
> communication, or any of its contents, is strictly prohibited. If you have
> received this communication in error, please notify the sender immediately and
> destroy or delete the original message and any copy of it from your computer
> system. If you have any questions concerning this message, please contact the
> sender.
> ===============================================================================>

From: Bevi Chagnon | PubCom
Date: Mon, Jun 06 2011 11:06AM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Jennifer wrote:
" we're wondering which standards they'll use to test by."

If the notice came from a U.S. Federal government agency (and I'm assuming
it did), you can only be assessed according to current Section 508 standards
and guidelines, not the forthcoming ones due out late this year/early next
year.

The U.S. Access Board writes the "regs" (or standards) for accessibility.
The current standards are here:
http://www.access-board.gov/508.htm (look under "current standards")

The current standards were enacted 10 years ago, long before WCAG 2.0 was
released. Therefore if you're meeting WCAG 2.0 now, you probably will pass
the current standards test.

Keep in mind that the forthcoming new standards will encompass WCAG 2.0, so
you'll be in good shape when they are released down the road. However, the
testers might make recommendations for future compliance under the new
standards.

And Duff's comment about PDFs is critical: The current standards are vague
about PDFs but the industry is now taking the viewpoint that anything that
can be stored or viewed via web technology must be accessible, and that
includes PDFs, Word documents, Powerpoints, Excel spreadsheets...the whole
enchilada.

This loophole will be closed when the new standards are released. Thank
goodness!

Jennifer wrote:
" Do they use real people to test objectively? Or do they run it through a
validator?"

Yes, and yes.

--Bevi Chagnon

From: Karlen Communications
Date: Mon, Jun 06 2011 11:12AM
Subject: Re: Section 508 Testing/Section 508 Refresh
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I would second that.

The refresh of Section 508 includes all file formats with specifics on what
the standards for an accessible document are. While I disagree with their
position on Excel/spreadsheet based documents as we move forward it is
always a good idea to include all content in an audit/quality assurance
process.

Validation tools can only tell you if the coding is missing anything and
testers with a specific checklist should also go through the digital
content. I say testers with specific goals/checklists because we all read
content differently and you are looking for global "compliance' rather than
adaptive technology or person specific compliance...which is not possible to
achieve.

Cheers, Karen

From: John E Brandt
Date: Mon, Jun 06 2011 11:39AM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Don't forget to make sure all videos are captioned and all audio file
transcribed.

If you use animations or Flash, you are going to have to ensure these are
also accessible.

John E. Brandt
www.jebswebs.com
= EMAIL ADDRESS REMOVED =
207-622-7937
Augusta, Maine, USA


From: Morin, Gary (NIH/OD) [E]
Date: Mon, Jun 06 2011 12:09PM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Videos and multimedia need Audio-Description, in addition to captioning (transcriptions being provided only for audio-only files). And the multimedia players need to be tested - rarely are they accessible to those of us who use speech recognition, as well as to screen readers, from what I've heard. Audio Description is no less required, just less provided.

Gary M. Morin, Program Analyst
NIH Office of the Chief Information Officer
10401 Fernwood Rd, Room 3G-17
Bethesda, MD 20892, Mail Stop: 4833

(301) 402-3924 Voice, 451-9326 TTY/NTS
Videophone (240) 380-3063; (301) 402-4464 Fax

NIH Section 508 Team: mailto: = EMAIL ADDRESS REMOVED = ?subject=Section 508 Help or, for Section 508 Guidance, http://www.hhs.gov/web/508/index.html

WHAT IF THE FIRST QUESTION WE ASKED WAS, "WHAT IS SO UNIQUE ABOUT THIS SITUATION THAT IT JUSTIFIES EXCLUSION? INSTEAD OF, "HOW MUCH DOES IT COST TO MAKE IT ACCESSIBLE?"


From: Angela French
Date: Mon, Jun 06 2011 12:36PM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Any idea how they make their selection process on whose site is going to be audited?

From: McDonald, Jennifer
Date: Mon, Jun 06 2011 12:42PM
Subject: Re: Section 508 Testing/Section 508 Refresh
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US Department of Education did the notifying.

All great feedback, thanks everyone. I'm feeling pretty good about
where we are as we've been paying attention and trying to make things
accessible as we update products and applications.

Jeni

From: John E Brandt
Date: Mon, Jun 06 2011 1:03PM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Gary,

Are you saying that the "testing" that Jennifer's group will be experiencing
will include all parts of the Section 508 Standards? She specifically
referenced "... our website and web-based applications will be tested ..."

There are a number of subsections in Subpart B: Technical Standards which
includes the Video and multimedia products (substandard 1194.24) - where the
reference to audio descriptions is made. Subsection 1194.22 that deals with
Web-based intranet and internet information and applications does not appear
to have the audio description requirement.

I am curious since I've always heard that Section 508 only really applies to
federal agencies and the Post Office. Many states and organizations have
adopted the Subsection 1194.22 for the accessibility standard for their
websites, but not the other standards.

If the Fed is now auditing all of their contractors for full compliance to
all of standards of Section 508 - that would be BIG news.

John E. Brandt
www.jebswebs.com
= EMAIL ADDRESS REMOVED =
207-622-7937
Augusta, Maine, USA


From: Ritz, Courtney L. (GSFC-7500)
Date: Mon, Jun 06 2011 1:24PM
Subject: Re: Section 508 Testing/Section 508 Refresh
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This is indeed very interesting.
When I do Section 508 testing, I usually stick with the checkpoints in 1194.22.
But when we were filling out the recent DOJ Section 508 survey, in the section pertaining to 2 Web sites and 2 Web applications to be tested, there were definitely more than the 16 checkpoints listed. I believe the extra ones came from 1194.24, including those pertaining to captioning and audio description. Someone correct me if I'm wrong, though. (grins)

Courtney

From: Morin, Gary (NIH/OD) [E]
Date: Mon, Jun 06 2011 1:36PM
Subject: Re: Section 508 Testing/Section 508 Refresh
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The issue of Federal-only obligation did surprise me or catch my attention in the initial posting! To my knowledge, Section 508 still only applies to Federally-conducted programs, and not even Federally-funded programs. We don't, for example, advise our grantees that they must comply with Section 508 (only the other Sections of the Rehab Act that they've long been required to follow), though we encourage it where we can. Not sure what the "Section 508 Refresh" will say about this.

I think I was assuming (ok, not a great action, I admit) that they were adopting the Sec. 508 standards as their working standard. I think one of the other responses, from Angela, was Who did the notifying? If Jennifer's work is done on behalf of the Dept. of Education - are they funded or contracted to provide websites that are owned by Education (which, then, do need to be Section 508-conformant) or is Jennifer's organization being funded by Dept of Education but to work their own work (e.g., their websites are not *.gov)? Is the work being done for a federally-conducted project or solely a federally-funded one? Why is testing for Section 508 conformance being done? As a requirement or simply benchmarking?

* The company that I work for has been notified that our website and web-based applications will be tested to determine "how well it complies with the standards of the Rehabilitation Act of 1973 as amended in 1998". We do work on behalf of the Department of Education. Has anyone been through this before? While we feel confident that we're indeed accessible, we're wondering which standards they'll use to test by. I've been performing all of my analysis based on WCAG 2 - and I've been researching Section 508 Refresh. Do they use real people to test objectively? Or do they run it through a validator?
* If anyone has had any experience with a government accessibility review I would love to hear about it.

I only mentioned the audio-description and the media player accessibility since captioning was mentioned. Clearly, if there is no multimedia, none of those apply.

Gary M.



From: Pollard, Larry W. (DRS)
Date: Mon, Jun 06 2011 2:33PM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Good Afternoon Courtney I hope the following give you a better
understanding. This is what we run as far as accessibility testing.

http://www.vadsa.org/scorecard/

The WAI / Scorecard assessment is an annual report that is run by the
Virginia Department of Rehabilitative Services for all state agencies.
The purpose of the report is to give each agency a detailed report on
how accessible their site is to people with disabilities such as vision
impaired consumers. For example, if you are blind, you might use an
automated screen reader. The screen reader, a software program, not only
reads aloud the body text on a page, but also describes Web elements
such as images. However, in order for a screen reader to describe images
and other Web elements to the user, the HTML or other markup language
used to code the page must make this information available to the screen
reader. This site was developed in order to provide statistical analysis
for accessibility (WCAG 1 / Section 508) and detailed reporting for all
commonwealth executive branch agency web sites. This site assesses
compliance with the World Wide Web Consortium's (W3C) Web Content and
Accessibility Guidelines (WCAG) Level A and Federal Section 508 web
standards. Compliancy is rated through a series of in-depth site
reports. All site reports were created using ACCVerify by HiSoftware.
The settings used in ACCVerify combine the requirements for WCAG
Priority 1 along with suggestions for potential issues with priorities 2
and 3. In addition, Section 508 components are added in order to
consolidate all tests into one report. To review a detailed side-by-side
analysis of WCAG 1.0 and Section 508 standards, please visit
http://www.jimthatcher.com/sidebyside.htm#WCAGView .
Accessibility today has two meanings for Web content:
Information is accessible when it meets U.S. federal regulations for Web
content. As of June 25, 2001, federally maintained Web sites and
networks are required to comply with these accessibility standards
Information is also accessible when it achieves the highest level of
usability. In addition to federal regulations, there are many more
suggestions that help everyone to find and use Web-based information.
For additional information, contact the W3C(r) or visit
http://www.w3.org/WAI
















Larry. Pollard
Accessibility Webmaster
Department of Rehabilitative Services

From: Angela French
Date: Mon, Jun 06 2011 2:48PM
Subject: Re: Section 508 Testing/Section 508 Refresh
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Larry can you please define "...and networks"




Accessibility today has two meanings for Web content:
Information is accessible when it meets U.S. federal regulations for Web content. As of June 25, 2001, federally maintained Web sites and networks are required to comply
The settings used in ACCVerify combine the requirements for WCAG Priority 1 along with suggestions for potential issues with priorities 2 and 3. In addition, Section 508 components are added in order to consolidate all tests into one report. To review a detailed side-by-side analysis of WCAG 1.0 and Section 508 standards, please visit http://www.jimthatcher.com/sidebyside.htm#WCAGView .
Accessibility today has two meanings for Web content:
Information is accessible when it meets U.S. federal regulations for Web content. As of June 25, 2001, federally maintained Web sites and networks are required to comply with these accessibility standards Information is also accessible when it achieves the highest level of usability. In addition to federal regulations, there are many more suggestions that help everyone to find and use Web-based information.
For additional information, contact the W3C(r) or visit http://www.w3.org/WAI
















Larry. Pollard
Accessibility Webmaster
Department of Rehabilitative Services

From: Ryan E. Benson
Date: Tue, Jun 07 2011 8:36AM
Subject: Re: Section 508 Testing/Section 508 Refresh
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When I conduct a site audit/review, I bring the whole bulk of Section
508 in, and apply what is needed. Of course I start with 1194.22. If
the person comes to me and tells me that it is an application, or
Software As A Service (SAAS), then 1194.21 jumps aboard. If I spot or
am told there is a video player on the page, again 1194.21 is used as
well as 1194.24. Most of the time there is a manual or downloadable
help file given, then 1194.41 is used. We have a checklist for each
section, as well as most document types.

--
Ryan E. Benson



On Mon, Jun 6, 2011 at 3:32 PM, Morin, Gary (NIH/OD) [E]
< = EMAIL ADDRESS REMOVED = > wrote:
> The issue of Federal-only obligation did surprise me or catch my attention in the initial posting!  To my knowledge, Section 508 still only applies to Federally-conducted programs, and not even Federally-funded programs.  We don't, for example, advise our grantees that they must comply with Section 508 (only the other Sections of the Rehab Act that they've long been required to follow), though we encourage it where we can.  Not sure what the "Section 508 Refresh" will say about this.
>
> I think I was assuming (ok, not a great action, I admit) that they were adopting the Sec. 508 standards as their working standard.  I think one of the other responses, from Angela, was Who did the notifying?  If Jennifer's work is done on behalf of the Dept. of Education - are they funded or contracted to provide websites that are owned by Education (which, then, do need to be Section 508-conformant) or is Jennifer's organization being funded by Dept of Education but to work their own work (e.g., their websites are not *.gov)?  Is the work being done for a federally-conducted project or solely a federally-funded one?  Why is testing for Section 508 conformance being done? As a requirement or simply benchmarking?
>
> *       The company that I work for has been notified that our website and web-based applications will be tested to determine "how well it complies with the standards of the Rehabilitation Act of 1973 as amended in 1998".  We do work on behalf of the Department of Education. Has anyone been through this before?  While we feel confident that we're indeed accessible, we're wondering which standards they'll use to test by.  I've been performing all of my analysis based on WCAG 2 - and I've been researching Section 508 Refresh.  Do they use real people to test objectively?  Or do they run it through a validator?
> *       If anyone has had any experience with a government accessibility review I would love to hear about it.
>
> I only mentioned the audio-description and the media player accessibility since captioning was mentioned.  Clearly, if there is no multimedia, none of those apply.
>
> Gary M.
>
>
>
>