Thread Subject: Re: Agency responsibility for providing documentation (formerly "today's question")

Note

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From: terry.weaver@gsa.gov
Date: Fri, Jan 12 2007 8:55 AM

In support of David's comments below, the Buy Accessible Wizard and the
training provided by GSA all tell government buyers that they should
require all electronic documentation delivered under the contract to meet
the web provisions under the Standards. This is a current government best
practice; I am including a sample below of suggested RFP language:

All reports and deliverables provided in electronic media shall be
accessible to people with disabilities in accordance with the relevant
accessibility standards (see below) referenced in Section 508 of the
Rehabilitation Act (29 U.S.C. 794d), as amended by the Workforce
Investment Act of 1998 (P.L. 105-220), August 7, 1998.
1194.22 Web-based Intranet and Internet Information and Applications
1194.31 Functional Performance Criteria
1194.41 Information, Documentation, and Support




On Thu, 11 Jan 2007 15:35:15 -0800
Dawn Wilcox = EMAIL ADDRESS REMOVED = said:

"I interpret 1194.41 (a) to mean the manufacturer provides it and pays
for it. but we could make it more obvious by adding - the manufacturer
pays for and the agency requests alternate formats. Dawn Wilcox CCLVI"

Access Board's response:

No, the 508 Standard does not specify who creates and pays for it. The
standard falls on the shoulders of federal agencies to provide it (the
product support documentation in alternative formats) if requested.

A best practice might be for an agency experienced in this subject to
request, in their RFP, an electronic convertible version of the product
support documentation. The TEITAC may consider recommending an advisory
note on this subject.

Remember that you can recommend lots of advisory notes. Your
recommendations, needn't be limited to changes in the actual standards
and guidelines.

Next, remember that you are providing recommendations for both 255 and
508. These laws address documentation differently, and both subjects
could be addressed in your discussions. 255 requires the telecom
manufacturers to provide their product support documentation in
alternative formats at no additional charge if requested.

Therefore, in connecting these dots, if I were a federal agency
specifically buying a telecom product, I would expect the telecom
manufacturer to already be up to speed on this subject and would inquire
how they are meeting their 255 documentation requirement.

You can't have a requirement in the 508 standards that tells
manufacturers what to do. That reflects confusion about 508. 508 is a
purchasing requirement, not a production requirement.

David Baquis
Accessibility Specialist
U.S. Access Board
1331 F Street, NW, #1000
Washington, DC 20004
800-USA-ABLE; (202) 272-0013 (voice)
www.access-board.gov; = EMAIL ADDRESS REMOVED = "Leading the way to
excellence in accessibility"

"Thank you for your questions concerning section 508 of the
Rehabilitation Act Amendments of 1998. Section 508 authorizes the
Access Board to provide technical assistance to individuals and Federal
departments and agencies concerning the requirements of this section.
This technical assistance is intended solely as informal guidance; it is
not a determination of the legal rights or responsibilities of entities
subject to section 508."

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