Thread Subject: Re: FW: Subpart A- Draft - Comparable AccessDefinition
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From: David Poehlman
Date: Wed, Mar 28 2007 1:55 PM
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for that matter, what is access.
On Mar 21, 2007, at 4:32 PM, Robinson, Norman B - Washington, DC wrote:
What is comparable access?
Robert Baker's post on March 16th 2007 on this list (teitac-
= 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
Â§ 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%
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
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
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