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

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From: David Poehlman
Date: Mon, Mar 19 2007 1:55 PM

Hi Norman and all,

I'd like to offer a different aapproach. What we need are guidance/
standards if you will that provide a roadmap for formats to be
compliiant. We need to also target the requestor by functionality.
If braille meets the need, it should be braillee and not only
braille, but grade1 if that is what is needed. If casset, asci,,
other commonly used and or open formats meet the need, that should be
supplied. In other words, do away with alternate formats altogether
and talk about compliant formats if you will.

On Mar 19, 2007, at 3:41 PM, Robinson, Norman B - Washington, DC wrote:


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:teitac-
= 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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