Thread Subject: Re: Final? draft of 1194.41a, b,and c (was discussion of who pays for alternate format)

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From: Debbie Cook
Date: Mon, Mar 19 2007 12:55 PM

I have always preferred to require an accessible electronic format which can
be converted to other alternative formats on demand as an accommodation.
That electronic format is dictated by the audience. If it's federal
employees, it's reasonable to assume that they have provided applications
for reading it. If it's the public, then there are fewer options. Doesn't
preclude someone from still requesting an accommodation of the material in a
particular format because they cannot use the accessible one. If I create an
accessible PDF but lots of users can't use it because they don't have enough
PC power to run theaccess tools etc. then I'll get more requests for
alternative formats and I might want to reconsider in the future.
----- Original Message -----
From: "Robinson, Norman B - Washington, DC" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC documentation and technical support subcommittee"
< = EMAIL ADDRESS REMOVED = >
Sent: Monday, March 19, 2007 12:41 PM
Subject: Re: [teitac-documentation] Final? draft of 1194.41a, b,and c (was
discussion of who pays for alternate format)



An observation: what is the definition of alternate formats or alternate
methods?

1. What would be examples of how this should be implemented?
e.g.: We provide documentation in PDF format that (we believe)
meets all the 1194 subpart B and C requirements. What happens with the users
that can't open a PDF v 12 using their assistive technology or it doesn't
work on their platform/operating system? That is, what happens when the
end-user deems the format unacceptable? If I don't run MS Office at home, is
a MS Word document acceptable? What is the acceptable alternate format for
blueprints? We've have a primitive approach to this in our USPS policy:
http://www.usps.com/cpim/ftp/hand/as508a/508a_c6.html#508hdr79.

2. Are we addressing the real world need for accessible electronic
formats (and not just Braille or other options)?

3. What would be examples of how this could be implemented in
undesirable ways?
e.g., We provide documentation in one format only, which our
legal council has deemed meets our legal requirements since [vendor specific
example] is commonly available. Assume there is no accessible plug-in for
[vendor specific format]. Assume the vendor software costs a significant
amount of money to obtain. Generally, I've found this is left until someone
actually makes a request, then the responsible program has to back-track
into satisfying the end-user's needs.

Who _legally_ determines what is an acceptable alternate format? Do
we expect when reasonable people disagree, the desired course of action
would be for the affected individual to file a Section 508 complaint? Do we
expect clarification in the next version of the Section 508 technical
standards that describes what the best practice or acceptable formats should
be allowed?

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 Michele
Budris
Sent: Friday, March 16, 2007 4:15 PM
To: TEITAC documentation and technical support subcommittee
Subject: [teitac-documentation] Final? draft of 1194.41a, b, and c (was
discussion of who pays for alternate format)


In the discussions of how to make clear who pays for alternate formats the
proposal was made to rewrite 1194.41a, b, and c to be the text below. In the
March 15, 2007 meeting it was agreed to make this the final version unless
issues are raised. Deadline for feedback is Friday, March 26, 2007.



Subpart D -- Information, Documentation, and Support

§ 1194.41 Information, documentation, and support.

(a) To enable Federal agencies to provide product support documentation to
end-users in an accessible format, Federal agencies shall require that all
documentation supporting the product, including but not limited to reports,
system documentation and end user training or technical support materials
shall conform the relevant accessibility provisions in 1194 Subparts B and
C.

(b) Federal agencies shall provide end-users access to a description of the
accessibility and compatibility features of products in alternate formats or
alternate methods upon request.

(c) Support services for products shall accommodate the communication needs
of end-users with disabilities

Best Practice : If the documentation supporting the product, reports or
other documentation are to be provided via a contract, then the contract
must include this requirement.

If the descriptions for the end-users regarding the accessibility and
compatibility features of products in alternate formats are to be provided
via a contract, then the contract must include this requirement.



Michele





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