Thread Subject: Contribution to the General InterfaceAccessibility Subcommittee
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From: Jim Tobias
Date: Fri, Oct 20 2006 6:25 AM
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One of our tasks is to look across the current 508 structure, the 6 product
categories, to find common elements that could be brought together, or at
least thought about consistently. One reason is that there is some
duplication within the current structure. For example, the provisions about
"mechanically operated controls and keys" appear in Telecom, Desktop
Computers, and Closed Products. Another reason is that the product category
structure itself is under continual assault by the shifting, morphing,
converging ICT product ecosystem. It could be argued that all 6 categories
are less clear and useful than they were a few years ago.
In fact, the initial Access Board NPRM included provisions stated this way,
under several functional categories in addition to the product categories.
I have put together a spreadsheet entitled "TEITAC - Functional Components
View", which demonstrates one approach to provisions that span several
product categories. It can be found online at Google's new "Docs and
[Sidenote: All comments on the accessibility of this Google web app are
welcome, but should be sent directly to me rather than to this list. If you
cannot use the spreadsheet online, you may get better results if you
download it. If downloading it is also difficult, tell me and I will send
you a copy.]
The spreadsheet has 3 worksheets:
1. The "current list" worksheet is just the 1194.21 to 1194.26 provisions in
their current order, with an additional column indicating how they might be
2. The "re-grouped" worksheet moves the provisions into those categories.
For example, all provisions that refer to color or contrast are placed
together, regardless of which product category they came from.
3. The "functional components" worksheet adds columns that indicate what
kind of product feature or component would be addressed by which provisions.
Looking at the relationship the other way, the worksheet shows which
provisions would be applied to products with which components. The cells
where there is such a relationship are marked with the letter "Y". For
example, the provisions on information in color only apply to products with
visual displays, and only if those displays use color.
Please understand that this is just an initial attempt, and does not claim
to be exhaustive.
I would like some time on the upcoming Subcommittee call, Monday 23 October,
to go over this approach.
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