Thread Subject: Re: Proposal 21(b) Focus

Note

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From: Deborah Buck
Date: Mon, Nov 27 2006 2:40 PM

I would strongly encourage the group to keep the definition of assistive
technology consistent with other federal statutes. Much effort has been made
over the last 15 years to promote a consistent definition of AT and
modifying the term to be specific for 508 will not necessarily have the
impact expected or hoped for. The Definition of AT in the Assistive
Technology Act (PL 105-394) is replicated in the Workforce Investment Act
(WIA), Individuals with Disabilities Education Act (IDEA), the Developmental
Disabilities Act (DD Act) and other federal statutes. Furthermore, I think
Dave Capozzi gave sound advice when he suggested that the definitions not
drive the standards. The definitions should be used as a foundation and the
standards should be clear enough in their own right.

The issue at hand that we need to address is that the 508 rule currently
cites the incorrect definition of AT. Under the AT Act there are 3
definitions related to AT: AT Device, AT Service and AT (which is references
AT Device and Service). The AT Act also includes a definition for Universal
Design. The term AT Device is broad enough to cover an array of products to
increase function or access.

ASSISTIVE TECHNOLOGY-The term 'assistive technology' means technology
designed to be utilized in an assistive technology device or assistive
technology service.

ASSISTIVE TECHNOLOGY DEVICE-The term 'assistive technology device' means
any item, piece of equipment, or product system, whether acquired
commercially, modified, or customized, that is used to increase, maintain,
or improve functional capabilities of individuals with disabilities.

ASSISTIVE TECHNOLOGY SERVICE-The term 'assistive technology service' means
any service that directly assists an individual with a disability in the
selection, acquisition, or
use of an assistive technology device. Such term includes-
(A) the evaluation of the assistive technology needs of an
individual with a disability, including a functional evaluation of the
impact of the provision of appropriate assistive technology and appropriate
services to the individual in the customary environment of the individual;
(B) services consisting of purchasing, leasing, or otherwise
providing for the acquisition of assistive technology devices by individuals
with disabilities;
(C) services consisting of selecting, designing, fitting,
customizing, adapting, applying, maintaining, repairing, or replacing
assistive technology devices;
(D) coordination and use of necessary therapies,
interventions, or services with assistive technology devices, such as
therapies, interventions, or services associated with education and
rehabilitation plans and programs;
(E) training or technical assistance for an individual with
disabilities, or, where appropriate, the family members, guardians,
advocates, or authorized representatives of such an individual; and
(F) training or technical assistance for professionals
(including individuals providing education and rehabilitation services),
employers, or other individuals who provide services to, employ, or are
otherwise substantially involved in the major life functions of individuals
with disabilities.

UNIVERSAL DESIGN -The term 'universal design' means a concept or
philosophy for designing and delivering products and services that are
usable by people with the widest possible range of functional capabilities,
which include products and services that are directly usable (without
requiring assistive technologies) and products and services that are made
usable with assistive technologies.

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Lybarger,
Barbara (MOD)
Sent: Monday, November 27, 2006 3:25 PM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] [teitac-websoftware] Proposal 21(b) Focus

In the Assistive Technology definition, how about replacing "that increases
accessibility for an individual" with "and that enables an individual with a
disability to more independently interact with one or more specific aspects
of information technology."

It's more informative,
Barbara E. Lybarger, General Counsel
Massachusetts Office on Disability
One Ashburton Place, #1305
Boston, MA 02108
[617] 727-7440
[800] 322-2020
[617] 727-0965 FAX



From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim Tobias
Sent: Monday, November 27, 2006 10:44 AM
To: 'TEITAC Web/Software Subcommittee'
Cc: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] [teitac-websoftware] Proposal 21(b) Focus
The first 2 definitions are good, and I think we should add them to the list
of defined terms under Subpart A.

The third is more problematic:
-- there already are several definitions of AT
-- it may require a definition for "system"
-- it refers to "an individual", not specifying whether that person has a
disability. Also, does it really mean "any indvidual"?
-- it perpetuates the lack of a suitable definition of "accessibility"


***********
Jim Tobias
Inclusive Technologies
= EMAIL ADDRESS REMOVED =
+1.732.441.0831 v/tty
skype jimtobias
www.inclusive.com



From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Monday, November 27, 2006 10:15 AM
To: 'TEITAC Web/Software Subcommittee'
Subject: Re: [teitac-websoftware] Proposal 21(b) Focus
In the HFES and ISO work we found that there is no clear delineation between
software and platform anymore.

So we have adopted the following. (this is from HFES doc)


Category Description
Platform software
(the operating system and associated layers, and toolkits) Operating
system, drivers and associated software layers.
Includes Windowing Systems, libraries and associated toolkits that provide
or affect the user interface of other software (e.g. GNOME, KDE, Java
runtime, Visual Basic, applications executing scripts or hosting embedded
objects, etc.)
NOTE: If a software program uses its own routine to provide, override, or
replace OS driver functions then the application would need to conform to
related Platform Software provisions.

Application software
(which run on and make use of services provided by platform software)
Software not considered as part of the operating system or its
immediate layers. This includes "desktop" software bundled with an operating
system, personal productivity applications, development tools, Web browsers,
and other non-OS software.
Assistive Technology Hardware or software that is added to or
incorporated within a system that increases accessibility for an individual.
Some portions may function as platform software while other portions may
function as application software and would be covered above. Guidelines for
the design of assistive technology in general are outside the scope of this
document.



Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> Of Hoffman, Allen
> Sent: Monday, November 27, 2006 7:03 AM
> To: TEITAC Web/Software Subcommittee
> Subject: Re: [teitac-websoftware] Proposal 21(b) Focus
>
> Peter Korn wrote:
> "I wonder if it helps frame the issue by looking at a web
> browser as a "platform"."
>
> In W3C this is termed a user-agent, and there are user-agent
> accessibility guidelines completed. I think a clear
> demarcation of the lines between what the web-coding
> provides, and the accessibility features of the user-agent is
> important, as long as we are careful not to say, the coding
> doesn't need to do such and such because a browser can
> sometimes not pass it thru correctly. Maybe we should
> assemble the "stack" here to work from.
>
> So, top down, from the end-user to the other end we might have:
>
> assistive technology
> document object model/OS API(s)
> user-agent
> content stream of encoded information
> potential "just in time interpreter"
> Operating system w/ accessibility API(s)
>
> So should we consider what user-agent items should be developed that
> *must* be available to ensure some accessibility level based
> upon the other layers? If so, would this fall possibly in to
> a sub-portion of software/OS?
>
> For example a framework might be something like:
>
> When software is used to interpret and present (insert
> standards for web and other associated content streams),
> (insert requirement beyond other software requirements).
>
>
>
> Allen Hoffman
> Department of Homeland Security
> Office on Accessible Systems & Technology
>
>

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