Thread Subject: Re: Best Meets vs. Full Usein Functional PerformanceCriteria

From: awoolley@cusa.canon.com
Date: Wed, May 02 2007 7:30 AM

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Let's say there are three products that do not meet "full use" in the
functional criteria- and Product A meets the criteria 20%, Product B 50%,
and Product C 85%. Wouldn't it be beneficial to be able to identify this
last product?

By requiring "full use", my interpretation would be that a product would
either meet each criteria 100% or it doesn't meet it at all- Yes or No. I
think we need a way of recognizing products that have a higher level of
accessibility (specific to the functional criteria) than others. No?

Perhaps this is covered by the "in at least one mode" portion of the
criteria. If so, I'd appreciate the clarification.

For the benefit of others- these are the criteria under discussion....
1 Overall Functional Performance Criteria
Full use without Vision - in at least one mode (direct or via AT)
Full use with Low Vision without Audio - in at least one mode (direct or
via AT)
Full use without Hearing - in at least one mode (direct or via AT)
Full use with Enhance Audio - in at least one mode (direct or via AT)
Full use without Speech - in at least one mode (direct or via AT)
Full use with limited reach, strength or dexterity - in at least one mode
(direct or via AT)
Full use with cognitive, language or learning disabilities - in at least
one mode (direct or via AT)

Aubrey

Aubrey Woolley
Government Policy and Compliance Analyst
Government Marketing Division
Canon USA, Inc.
TEL: (703) 807-3158
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"Gregg Vanderheiden" < = EMAIL ADDRESS REMOVED = >
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05/02/2007 12:11 AM
Please respond to
TEITAC General Interface Accessibility Subcommittee
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To
"'TEITAC Subpart A Subcommittee'" < = EMAIL ADDRESS REMOVED = >,
"'TEITAC General Interface Accessibility Subcommittee'"
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cc

Subject
Re: [teitac-general] [teitac-subparta] Best Meets vs. Full Use in
Functional PerformanceCriteria






The ?full use? in the functional doesn?t conflict with ?best meets?. It
is the same as any other requirement. Fully meets would require that you
meet it. Best meets only requires that you meet them better than other
products.

This is the same as any other provision.


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



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[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
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Sent: Tuesday, May 01, 2007 3:29 PM
To: 'TEITAC General Interface Accessibility Subcommittee'
Cc: 'TEITAC Subpart A Subcommittee'
Subject: [teitac-subparta] Best Meets vs. Full Use in Functional
PerformanceCriteria

"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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