Thread Subject: Re: Best Meets vs. Full Use inFunctional PerformanceCriteria

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From: Debbie Cook
Date: Wed, May 02 2007 5:30 PM

The discussion of "full use" is pretty important with respect to products
with features that are closed to AT or for which there is no AT available. I
would assume that "full use" applies to the functions that people are
expected to have access to--not necessarily those only available to the
manufacturer or which are otherwise excluded by 508 provisions. And if, as
is most certainly the case, many products do not meet the full use criteria
on a Yes/No basis, then how do we measure that especially if most of the
technical standards do not apply or do not in themselves lead to the product
being accessible?
----- Original Message -----
From: < = EMAIL ADDRESS REMOVED = >
To: "'TEITAC General Interface Accessibility Subcommittee'"
< = EMAIL ADDRESS REMOVED = >
Cc: "'TEITAC Subpart A Subcommittee'" < = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, May 01, 2007 1:28 PM
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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