Thread Subject: Re: FW: Subpart A- Draft - Comparable AccessDefinition

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From: Robinson, Norman B - Washington, DC
Date: Wed, Mar 21 2007 1:55 PM

What is comparable access?

Robert Baker's post on March 16th 2007 on this list ( = EMAIL ADDRESS REMOVED = <mailto: = EMAIL ADDRESS REMOVED = > ) was a good post on this discussion that ended with agreement that "some attempt at creating a definition for comparable access is needed."

Again, what is comparable access? I don't speak about semantics, we can agree that equal access is needed, but how do we approach the issue scientifically? Is there a technical standard that will help us quantify comparable access? I do not think we have a technical definition, technical framework, or quantifiable approach to this issue.

How have we been treating the issue today and in the past?

Subpart A -- General
§ 1194.1 Purpose.
The purpose of this part is to implement section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d). Section 508 requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency. Section 508 also requires that individuals with disabilities, who are members of the public seeking information or services from a Federal agency, have access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities, unless an undue burden would be imposed on the agency.

I have found that it is not always clear to the reader of Section 508 that comparable access is equivalent access. Most people have settled on an approach that if the solution being proposed is _technically_ compliant with the Section 508 technical standards, then it is Section 508 compliant, and usability - specifically equivalent access - doesn't get considered. Comparable access is considered to mean access is possible. The technical standards do not address equivalence. For example, I have reviewed a web-based java application that was easy to use visually using a mouse, but required laborious, time-consuming, review by users using keyboards and screen readers. It took 3-6 seconds using a mouse, visually, but optimally 60 seconds to await screen refresh and reorient using a screen reader. Keyboard access was possible, but required the interface to reload before the next key press was detected. The product met all the technical standards. The implementation wasn't very usable.

Is comparable access about accessibility - the basic ability to be able to perform a function - or about the quality of the design?

So I will further comment that this is a problem with how Section 508 is written or organized. The purpose of Section 508 is lost when people rush to meet the Subpart B Technical Standards. It is only when we get to review and accept a product do we as "customers" enforce our interpretation as to what is acceptable to our users and to our purpose. I would like to ask the reader to review and consider where in the technical standards (Subpart B) does anything related to equivalent access, equivalent functions, equivalent timing, equivalent efficiency get addressed?

We won't get everyone believing in accessibility or solving the quality issue until we place the Subpart C - Functional Performance Criteria as the most important issue to Section 508 compliance and reduce the Subpart B - Technical Standards to specifics on how to quantify accessibility. The technical standards should be secondary to functional performance. This is a quality design issue. It has been my experience that the question of comparable or equal access is only asked if the solution is tested using accessibility techniques, either using assistive technologies or manually (e.g., keyboard access). The quality or design is being questioned. It isn't that the product doesn't meet the technical standards. It is a question of the usability of the product by users with disabilities, when those users are being compared to other users (e.g., paid or promotion by throughput or being evaluated on efficiency). When we start asking about the functional performance requirements *first* and the specific technical implementations second, we get a better outcome.

What Could the Section 508 technical standards require?

1. The Section 508 revision should clearly state equivalent access is required to meet the functional performance criteria. This can best be quantified via software performance testing or human factors evaluation. A test plan that includes testing for accessibility (IEEE Std 829-1998 <http://www.ruleworks.co.uk/testguide/documents/IEEE%20Standard%20for%20Software%20Test%20Documentation..pdf> with accessibility artifacts) would inspire confidence. There is a tie-in with vendor's product accessibility templates if we can clearly establish this link. Also note the IEEE Std deals with software and doesn't clearly address the hardware requirements.
2. My definition for comparable access: Comparable access is "E&IT has been tested using Section 508 functional performance criteria, and product performs equally well under all criteria." I know that isn't fair to E&IT that might be accessible but that hasn't tested, but I'm trying to focus on quality, and encourage something that can be measured.
3. The Section 508 Standards themselves should be reorganized to place emphasis on functional performance criteria, and indicate the technical standards are clarification on minimum technical requirements.

Wikipedia article on performance testing (http://en.wikipedia.org/wiki/Performance_testing) may be of use to the reader.

This is just my input. I certainly haven't solved this issue, but would appreciate any positive feedback and enhancement.


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

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