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Thread: WCAG 2.0 vs. Section 508

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From: David Ashleydale
Date: Mon, Aug 10 2009 6:05PM
Subject: WCAG 2.0 vs. Section 508
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Hi,

My company has been working towards complying with the WCAG 1.0
accessibility guidelines and recently we've decided to "upgrade" to WCAG
2.0. Since we're touching our standards anyway, I thought this might be a
good opportunity for us to throw in the ADA Section 508 guidelines, too. I
realize that there is a lot of overlap between the two standards, but I
thought it might be valuable to pick up the Section 508 items that are not
in WCAG 2.0.

My first question is, do you think this would be valuable, or do you think
it's sufficient to just use WCAG 2.0 and not bother with Section 508? Our
site does not currently provide services to the federal government -- we are
a commercial site. Although, if we ever did provide government services or
if commercial sites are ever explicitly added to Section 508, then it would
be nice to say that we are already in compliance.

My next question is, if we do add support for the Section 508 web
accessibility guidelines to our site's standards, what would be a good way
to deal with the priority levels? It's easy to use the 3 priority levels in
WCAG, but as far as I can tell, everything in Section 508 is of the same
priority level. Should I assume that all of the Section 508 guidelines are
of the highest priority level? Or maybe it would be a good strategy to use
WCAG's priority levels when the two standards are similar, and only assign
the highest priority level to those Section 508 guidelines that are unique.

Thanks for your thoughts,
David Ashleydale

From: Benjamin Hawkes-Lewis
Date: Mon, Aug 10 2009 6:45PM
Subject: Re: WCAG 2.0 vs. Section 508
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On 11/08/2009 01:02, David Ashleydale wrote:
> My next question is, if we do add support for the Section 508 web
> accessibility guidelines to our site's standards, what would be a good way
> to deal with the priority levels? It's easy to use the 3 priority levels in
> WCAG, but as far as I can tell, everything in Section 508 is of the same
> priority level. Should I assume that all of the Section 508 guidelines are
> of the highest priority level? Or maybe it would be a good strategy to use
> WCAG's priority levels when the two standards are similar, and only assign
> the highest priority level to those Section 508 guidelines that are unique.

Hmm.

I guess that depends on how you are using WCAG 2 Conformance Levels.

The purpose of WCAG 2's Conformance Levels is to allow sites to claim
conformance with subsets of WCAG 2 ("In order to accommodate different
situations that may require or allow greater levels of accessibility
than others"):

http://www.w3.org/TR/UNDERSTANDING-WCAG20/conformance.html#uc-conformance-whatis-head

If you are trying to work out what Conformance Level the WCAG Working
Group would have assigned a requirement /if/ it had been included in
WCAG 2.0, I suppose you could try evaluating the requirement with the
same criteria as the Working Group used:

http://www.w3.org/TR/UNDERSTANDING-WCAG20/conformance.html#uc-levels-head

But if you want to claim compliance with Section 508, you need to claim
compliance with all of Section 508.

If you failed to comply with a particular 508 requirement, it would make
no difference to your overall compliance whether your company asserted
the requirement was somehow equivalent to WCAG Conformance Levels 1, 2,
3, or beyond those Levels.

So what would be the point of the assertion?

If you must claim conformance with WCAG 2.0, you /must/ at least conform
to Level 1.

Therefore, if you must claim conformance with Section 508, you /must/
conform to all its requirements with the same force as you conform to
Level 1 of WCAG 2.0.

I suppose that's equivalent to saying you would need to "assume that all
of the Section 508 guidelines are of the highest priority level".

Compare the treatment of WCAG 1.0 within Section 508's text:

"The Board interprets paragraphs (a) through (k) of this section as
consistent with the following priority 1 Checkpoints of the Web Content
Accessibility Guidelines 1.0 (WCAG 1.0) (May 5, 1999) published by the
Web Accessibility Initiative of the World Wide Web Consortium …
Paragraphs (l), (m), (n), (o), and (p) of this section are different
from WCAG 1.0. Web pages that conform to WCAG 1.0, level A (i.e., all
priority 1 checkpoints) must also meet paragraphs (l), (m), (n), (o),
and (p) of this section to comply with this section."

http://www.section508.gov/index.cfm?FuseAction=content&;ID=12#Web

Does that help?
--
Benjamin Hawkes-Lewis

From: J. B-Vincent
Date: Mon, Aug 10 2009 6:55PM
Subject: Re: WCAG 2.0 vs. Section 508
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See http://www.tomjewett.com/accessibility/508-WCAG2.html for a good discussion of how WCAG 2.0 maps to 508.

--- On Mon, 8/10/09, Benjamin Hawkes-Lewis < = EMAIL ADDRESS REMOVED = > wrote:

From: Benjamin Hawkes-Lewis < = EMAIL ADDRESS REMOVED = >
Subject: Re: [WebAIM] WCAG 2.0 vs. Section 508
To: "WebAIM Discussion List" < = EMAIL ADDRESS REMOVED = >
Date: Monday, August 10, 2009, 5:44 PM

On 11/08/2009 01:02, David Ashleydale wrote:
> My next question is, if we do add support for the Section 508 web
> accessibility guidelines to our site's standards, what would be a good way
> to deal with the priority levels? It's easy to use the 3 priority levels in
> WCAG, but as far as I can tell, everything in Section 508 is of the same
> priority level. Should I assume that all of the Section 508 guidelines are
> of the highest priority level? Or maybe it would be a good strategy to use
> WCAG's priority levels when the two standards are similar, and only assign
> the highest priority level to those Section 508 guidelines that are unique.

Hmm.

I guess that depends on how you are using WCAG 2 Conformance Levels.

The purpose of WCAG 2's Conformance Levels is to allow sites to claim
conformance with subsets of WCAG 2 ("In order to accommodate different
situations that may require or allow greater levels of accessibility
than others"):

http://www.w3.org/TR/UNDERSTANDING-WCAG20/conformance.html#uc-conformance-whatis-head

If you are trying to work out what Conformance Level the WCAG Working
Group would have assigned a requirement /if/ it had been included in
WCAG 2.0, I suppose you could try evaluating the requirement with the
same criteria as the Working Group used:

http://www.w3.org/TR/UNDERSTANDING-WCAG20/conformance.html#uc-levels-head

But if you want to claim compliance with Section 508, you need to claim
compliance with all of Section 508.

If you failed to comply with a particular 508 requirement, it would make
no difference to your overall compliance whether your company asserted
the requirement was somehow equivalent to WCAG Conformance Levels 1, 2,
3, or beyond those Levels.

So what would be the point of the assertion?

If you must claim conformance with WCAG 2.0, you /must/ at least conform
to Level 1.

Therefore, if you must claim conformance with Section 508, you /must/
conform to all its requirements with the same force as you conform to
Level 1 of WCAG 2.0.

I suppose that's equivalent to saying you would need to "assume that all
of the Section 508 guidelines are of the highest priority level".

Compare the treatment of WCAG 1.0 within Section 508's text:

"The Board interprets paragraphs (a) through (k) of this section as
consistent with the following priority 1 Checkpoints of the Web Content
Accessibility Guidelines 1.0 (WCAG 1.0) (May 5, 1999) published by the
Web Accessibility Initiative of the World Wide Web Consortium …
Paragraphs (l), (m), (n), (o), and (p) of this section are different
from WCAG 1.0. Web pages that conform to WCAG 1.0, level A (i.e., all
priority 1 checkpoints) must also meet paragraphs (l), (m), (n), (o),
and (p) of this section to comply with this section."

http://www.section508.gov/index.cfm?FuseAction=content&;ID=12#Web

Does that help?
--
Benjamin Hawkes-Lewis

From: Christophe Strobbe
Date: Tue, Aug 11 2009 2:15AM
Subject: Re: WCAG 2.0 vs. Section 508
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Hi David,

At 02:02 11/08/2009, David Ashleydale wrote:
>Hi,
>
>My company has been working towards complying with the WCAG 1.0
>accessibility guidelines and recently we've decided to "upgrade" to WCAG
>2.0. Since we're touching our standards anyway, I thought this might be a
>good opportunity for us to throw in the ADA Section 508 guidelines, too. I
>realize that there is a lot of overlap between the two standards, but I
>thought it might be valuable to pick up the Section 508 items that are not
>in WCAG 2.0.
>
>My first question is, do you think this would be valuable, or do you think
>it's sufficient to just use WCAG 2.0 and not bother with Section 508?

While planning this kind of work it is important to bear in mind that
the current Section 508 was based on a draft of WCAG 1.0, and that
during the development of WCAG 2.0 there has been harmonisation work
between the WCAG Working Group and the committee that prepared the
update of Section 508 (i.e. the technical work, not the political
work). Based on what I've heard (nothing official), there won't be a
"new Section 508" within the next 12-18 months, but WCAG 2.0 appears
to be a stabler option right now.

Best regards,

Christophe


--
Christophe Strobbe
K.U.Leuven - Dept. of Electrical Engineering - SCD
Research Group on Document Architectures
Kasteelpark Arenberg 10 bus 2442
B-3001 Leuven-Heverlee
BELGIUM
tel: +32 16 32 85 51
http://www.docarch.be/
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