Thread Subject: Re: teitac-subparta BestMeets vs. Full UseinFunctional PerformanceCriteria

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From: awoolley@cusa.canon.com
Date: Thu, May 03 2007 4:25 PM

Hi Deborah,

I'd like to highlight your comment for the group:

"Full use in my mind means all and complete. If we mean something
else we should say that."

This is an important point. We really do need to clarify "full use" if
the intention is not a black and white determination.

Aubrey

Aubrey Woolley
Government Policy and Compliance Analyst
Government Marketing Division
Canon USA, Inc.
TEL: (703) 807-3158
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"Deborah Buck" < = EMAIL ADDRESS REMOVED = >
Sent by: = EMAIL ADDRESS REMOVED =
05/03/2007 11:37 AM
Please respond to
TEITAC General Interface Accessibility Subcommittee
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To
"'TEITAC General Interface Accessibility Subcommittee'"
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Subject
Re: [teitac-general] [teitac-subparta] teitac-subparta Best Meets vs. Full
UseinFunctional PerformanceCriteria






I don?t have the answer to this discussion, but it stimulated more
questions on my part. Subpart A is not governing principles- it is the
section that defines how the standards shall be applied. Despite the fact
this term ?full use? will be used in the functional performance section it
does define how the standards are applied and is an application issue. I
don?t think that the performance criteria section is the appropriate
section to address how access is determined. Based on your comment below ?
We wouldn?t want to have standard that said that a product met the
standard if only part of the product was accessible.? In reality isn?t
that what we have that in play right now? Is there a good reason why
these standards should be treated differently than the technical
standards? An if we acknowledge that under the performance criteria some
products will meet it better than others- then why apply a benchmark of
Full Use? Full use in my mind means all and complete. If we mean
something else we should say that.


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Thursday, May 03, 2007 2:07 AM
To: 'TEITAC Subpart A Subcommittee'
Cc: 'TEITAC General Interface Accessibility Subcommittee'
Subject: Re: [teitac-general] [teitac-subparta] teitac-subparta Best Meets
vs. Full UseinFunctional PerformanceCriteria

Sure

The term in question is in the performance criteria section ( not SubPart
A)
As such it is a criteria ? just like all the other ones. (not a governing
principle as in SubPart A)

?Full use? just means that the goal is to make all of the product
accessible. That is, to meet the standard as an accessible product the
person with a disability would be able to use all of the function of the
product not just part of it.

We wouldn?t want to have standard that said that a product met the
standard if only part of the product was accessible.


But like all of the provisions, it is possible that different products
might meet this provision to different degrees.

Some may be completely usable while others may be less. Like any other
provision, we presumably are looking for products that meet the most
provisions for as much of the product functionality as is possible.

Thanks

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



From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Laura Ruby
Sent: Wednesday, May 02, 2007 2:06 PM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] teitac-subparta Best Meets vs. Full
UseinFunctional PerformanceCriteria
Gregg ? can you provide a definition for ?full use?. I ran this term by a
couple of my 508 savvy colleagues in the product groups and they were very
confused. I am concerned in the same way Aubrey is about this term.
L

Laura Ruby
Director of Global Policy and Standards
Microsoft Accessible Technology Group
425-705-7098
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From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Wednesday, May 02, 2007 11:47 AM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] teitac-subparta Best Meets vs. Full Use
inFunctional PerformanceCriteria

Best meets goes in part A

The performance criteria are different. We shouldn?t be mixing the roles
of the two sections.


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



From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jasionowski,
Tony
Sent: Wednesday, May 02, 2007 10:54 AM
To: = EMAIL ADDRESS REMOVED =
Subject: [teitac-subparta] teitac-subparta Best Meets vs. Full Use
inFunctional PerformanceCriteria
Folks,
I also agree with Aubrey's comments that "Best Meets" is preferred over
"Full Use" in the Functional PerformanceCriteria for the reasons she
mentioned. As we all know there are many cases where "yes/no" or
"black/white" are not adequate or appropriate. We should encourage and not
stiffle accessibility improvements.
Tony

Tony Jasionowski
Senior Group Manager Accessibility
Panasonic Corporation of North America (PNA)
Technology Liason & Alliances Group (TLAG)
1E-6
One Panasonic Way
Secaucus, New Jersey 07094
Tel.: 201-348-7777
Fax: 201-348-7807
" = EMAIL ADDRESS REMOVED = " (new)
"www.panasonic.com"

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2. Re: [teitac-subparta]
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Message: 1
Date: Wed, 2 May 2007 09:21:38 -0400
From: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-subparta] [teitac-general] Best Meets vs. Full
Use in Functional PerformanceCriteria
To: "'TEITAC General Interface Accessibility Subcommittee'"
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Subcommittee'"
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Content-Type: text/plain; charset="iso-8859-1"
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 = >
Sent by: = EMAIL ADDRESS REMOVED =
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.


From: = EMAIL ADDRESS REMOVED =
[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
= EMAIL ADDRESS REMOVED =

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