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

Note

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From: Robinson, Norman B - Washington, DC
Date: Fri, Jan 12 2007 10:35 AM

I'll second that it is the _agency_ that Section 508 applies to and we
contract our vendors to provide services that support our requirements
(that include Section 508 provisions).

We have specific language we try to use that I'll share in case the
example helps clarify:

1.0 Section 508 Compliance

Section 508 is a legal requirement that requires federal
agencies, including the USPS, to procure Electronic and Information
Technology (EIT) that is accessible to persons with disabilities.
Section 508 establishes technical and functional standards that
eliminate the barriers in electronic technology and information.



Contractors must ensure the electronic products and information
delivered are accessible. Please refer to Section X.X.X, Accessibility
Requirements and Section X.X.X, Standards & Guidelines, handbooks USPS
AS-508 Section 508 & USPS AS-508-A Section 508 Technical Reference
Guide.



2.0 Maintenance and Support Requirements

To support the implementation of the Supplier solution, the
supplier will provide all system and training documentation in
electronic format acceptable to create new documentation in alternate
formats. Our target format is (X)HTML and use with a standards compliant
web-browser. [NOTE: Contracting officer should consider having technical
staff verify content can be easily created in HTML when a proprietary
file format is desired].

Note that we try to make the language as plain and simple as possible
for vendors to understand, assuming they don't have knowledge of Section
508. However we do typically provide references to the law in our own
guidance (AS-508 & AS-508-A) but feel vendors respond better to _OUR_
requirements than to what may seem to be an obscure legal reference. We
have other supporting requirements in our template language but this is
the one relevant to 1194.41(a) "Alternate Formats".



Regards,





Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service
phone: 202.268.8246



-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
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Sent: Friday, January 12, 2007 10:53 AM
To: TEITAC documentation and technical support subcommittee
Cc: = EMAIL ADDRESS REMOVED = ;
= EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-documentation] Agency responsibility for
providing documentation (formerly "today's question")



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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