Thread Subject: Re: todays question

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From: Jim Tobias
Date: Fri, Jan 12 2007 9:00 AM


First, I'm not sure that we can require that the vendor provide anything --
the whole burden of
508 falls directly on the agency; it's the agency's responsibility to
require the vendor to meet
the standards. So that means that the agency has to include accessible
documentation in
its RFP and contract language. At least, that's how I understand it....

Second, I think we can do a better job of specifying how to meet this need
if we start with
a few general principles:

1. To use Mike's example, agencies shouldn't have to tag PDF files provided
by a vendor. It's
reasonable to require tagged PDF and any other accessible format the agency
prefers, such
as HTML or ASCII or whatever. The principle here is that the vendor is
closer to this part of
the responsibility, since they are the "publisher".

2. It may not be reasonable to require vendors to provide braille manuals,
since they may not
have braille production facilities. Agencies -- especially those agencies
that employ blind
people who use braille -- are closer to this part of the responsibility in
that they may already
have braille production facilities. The vendor, however, should provide the
documentation in
such a form that it can be readily brailled without much additional effort.
So if the vendor
provides a file of the documentation pre-formatted for braille, and the
agency takes that file
and produces a braille document, that seems like a good balance.

3. Certain other related functions may fit better on the vendor side,
especially pagination
(for both braille and large print) and a text description of all images
where the information
does not already appear in the text of the documentation.


******
Jim Tobias
Inclusive Technologies
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+1 732.441.0831 voice/tty
skype jimtobias
+1 908.907.2387 mobile




_____

From: Fratkin, Mike [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Friday, January 12, 2007 10:28 AM
To: TEITAC documentation and technical support subcommittee
Subject: Re: [teitac-documentation] todays question


I concur with this approach that as a minimum the vendor be required to
supply an electronic version. However, I would add that this electronic
version must be in an accessible format. We have required this in the past
which has met with mixed results as vendors do not seem to understand what
"accessible format" means so there probably needs to be some additional
guidance. Agencies should not have to be responsible for interpreting what
the alt text, for example, should be for images or screen shots. Agencies
should not have to be responsible for properly tagging PDF documents.

Mike Fratkin
Social Security Administration

[Barbara wrote:]

The bottom line is that alternative formats must be available. Depending on
the actual set of parties involved it varies which one is in the best
position to produce the a particular format. What about leaving it open as
a point of negotiation, with the agency ultimately responsible that the
alternative formats be produced as needed and the vendor obliged to at
minium provide digital copy that can be used to do the formating?


Barbara Lybarger

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = on behalf of Debbie Cook
Sent: Thu 1/11/2007 6:48 PM
To: TEITAC documentation and technical support subcommittee
Cc:
Subject: Re: [teitac-documentation] todays question



I think that providing alternative formats is an accommodation
responsibility of the gency. And, I think there re types of requests for
alternte formats which may go beyond htose we traditionally think of
particularly when it ocmes to cognitive accommodation. But, having said all
that, I do believe the manufacturer has the obligation to create
environments where alternative formats can be readily produced. So I think a
requirement more that that for text books where the manufacturer has to
provide digital formats is more appropriate and probably more likely to go
through than expecting every manufacturer to produce the variants of
alternative format that might be requested.
----- Original Message -----
From: "Thomas Brett" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC documentation and technical support subcommittee"
< = EMAIL ADDRESS REMOVED = >
Sent: Thursday, January 11, 2007 3:42 PM
Subject: Re: [teitac-documentation] todays question


I agree that the standard should explicitly state that the manufacturer pays
for the alternate format.
----- Original Message -----
From: Dawn Wilcox
To: = EMAIL ADDRESS REMOVED =
Sent: Thursday, January 11, 2007 6:35 PM
Subject: [teitac-documentation] todays question


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



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