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

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From: Deborah Buck
Date: Fri, May 04 2007 3:05 PM

That is how Best Meets is determined if I'm not off base. Agencies are not
limited to purchasing only those products that meet all of the standards.
It is the goal of agencies to purchase products that meet their business
requirements and that meet ALL of the 508 standards that are appropriate to
the development or acquisistion. However, if a product doesn't meet all of
the standards, a determination is made as to which product Best Meets. This
means that the product they select may meet some of the standards, not all
of the standards, but more than the other products under consideration. They
are able to purchase the products because it Best Meets the standard even if
"only part of the product was accessible". As I said before some agencies
institute a prioritization so that they can increase the likelihood that
they select products that meet what they consider to be critical standards.



-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Friday, May 04, 2007 12:51 AM
To: 'TEITAC General Interface Accessibility Subcommittee'
Subject: Re: [teitac-general] [teitac-subparta] teitac-subparta Best Meets
vs. Full UseinFunctional PerformanceCriteria



Hi Deborah,



You asked.

"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?



I don't follow you. If only part of the product meets a technical
standard, the product is not deemed to have conformed. Something isn't
judged to be screen reader compatible or have enough contrast or whatever if
only part of the product is.



Is that what you are saying or something else?



Thanks.




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






_____


From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah Buck
Sent: Thursday, May 03, 2007 10:38 AM
To: 'TEITAC General Interface Accessibility Subcommittee'
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

<mailto: = EMAIL ADDRESS REMOVED = > = EMAIL ADDRESS REMOVED =

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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1. Re: [teitac-general] Best Meets vs. Full Use in Functional
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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'"
< = EMAIL ADDRESS REMOVED = >, "'TEITAC Subpart A
Subcommittee'"
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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 = >
Sent by: = EMAIL ADDRESS REMOVED =
05/02/2007 12:11 AM
Please respond to
TEITAC General Interface Accessibility Subcommittee
< = EMAIL ADDRESS REMOVED = >



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
= EMAIL ADDRESS REMOVED =
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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