Thread Subject: Best Meets vs. Full Use in Functional PerformanceCriteria
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From: awoolley@cusa.canon.com
Date: Tue, May 01 2007 2:40 PM
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"Best meets" is used by the federal government and some states to
determine which products to procure to comply with Section 508 (in cases
where there are no products meeting all applicable standards). Based on
proposals from the Subpart A Subcommittee (See
http://teitac.org/wiki/Subpart_A:Application), there is support for using
a best meets approach in the next version of the standards.
However, including the term "full use" in the Functional Performance
Criteria draft language (1194.31 a, b, c, d, e) appears to be in conflict
with this principal.
(http://teitac.org/wiki/General_April_survey-report,
http://teitac.org/wiki/RESULTING_DRAFT)
For any E&IT products not able to meet these criteria 100%, the vendor
would have to indicate "does not meet" on any 508 documentation, such as
the VPAT. Therefore, it may be more difficult for agencies to determine
which product "best meets" 508 for those product categories where there
are no products reaching the 100% bar.
The addition of new accessibility features in products would also not be
encouraged unless they allowed full use of the E&IT. This is discouraging
for manufacturers who have the goal of incorporating new accessibility
features over time.
"Full use" is a very high bar. For many large office products, none of
our users have access to ALL the features. Some modes can be accessed by
the manufacturer's/dealer's authorized service engineers only for safety
purposes. For these practical reasons, removing the term "full" is
recommended. Other alternatives welcome.
Aubrey
Aubrey Woolley
Government Policy and Compliance Analyst
Government Marketing Division
Canon USA, Inc.
TEL: (703) 807-3158
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