Thread Subject: Re: 1194.3 (e)
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From: Robinson, Norman B - Washington, DC
Date: Mon, May 07 2007 9:50 AM
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William Loughborough asked "What has been decided (and by whom) if some
particular requirement might
"require a fundamental alteration"?"
The agency does so.
If you care to read the preamble to Section 508:
http://www.access-board.gov/sec508/preamble.htm, Paragraph (e) states
that compliance with this part does not require a fundamental alteration
in the nature of a product or service or its components. The comments
discussed in the preamble state fundamental alteration is an appropriate
exception for inclusion in the standards. It means a change in the
fundamental characteristic or purpose of the product or service, not
merely a cosmetic or aesthetic change. For example, an agency intends to
procure pocket-sized pagers for field agents for a law enforcement
agency. Adding a large display to a small pager may fundamentally alter
the device by significantly changing its size to such an extent that it
no longer meets the purpose for which it was intended, that is to
provide a communication device which fits in a shirt or jacket pocket.
For some of these agents, portability of electronic equipment is a
paramount concern. Generally, adding access should not change the basic
purpose or characteristics of a product in a fundamental way.
This is why it is so very important for agencies to define their
business requirements before they search for solutions. Otherwise if you
make a purchase of E&IT that isn't fully accessible, you can't defend
why you made your purchase choices, why the product you select wasn't
available in the market, why and undue burden applies, or why any other
general exception might apply.
Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of William
Sent: Sunday, May 06, 2007 11:37 PM
To: TEITAC General Interface Accessibility Subcommittee
Subject: [teitac-general] 1194.3 (e)
And then there's the subject provision which could be construed as a
backdoor to avoid "inconvenient accessibility": "This part shall not be
construed to require a fundamental alteration in the nature of a product
or its components."
What has been decided (and by whom) if some particular requirement might
"require a fundamental alteration"?