Thread Subject: Re: Agency responsibility forprovidingdocumentation (formerly "today's question")

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From: Jim Tobias
Date: Fri, Jan 12 2007 10:25 AM

Thanks, David, for this excellent guidance.

This issue seems to me to be one of those that is just outside the scope
of the standards, but one which TEITAC might well comment on for the sake
of improving implementation. That is, perhaps we cannot require agencies
to require accessible documentation from vendors, but we *can* suggest
several best practices that will allow agencies to meet their accessible
documentation responsibilities.

******
Jim Tobias
Inclusive Technologies
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> -----Original Message-----
> From: Baquis David [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Friday, January 12, 2007 10:43 AM
> To: = EMAIL ADDRESS REMOVED =
> Subject: [teitac-documentation] Agency responsibility for
> providingdocumentation (formerly "today's question")
>
> 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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