Thread Subject: Re: Applicability of Functional Performance Criteria

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From: Robinson, Norman B - Washington, DC
Date: Tue, Jun 05 2007 2:15 PM

Phill,

Is your concern that the functional performance criteria (FPC), by offering the "or support for assistive technology used by people who are ...shall be provided" clause, fails to define the specific technical requirements for a particular type of assistive technology?

It is often important to focus on the end goal of accessibility and the FPC language does that. If we were to choose "§ 1194.21 Software applications and operating systems: (a) When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually." we might have situations where developers can use that as a test condition and demonstrate functions are executable from a keyboard, but requires user vision. The § 1194.31 Functional performance criteria: (a) At least one mode of operation and information retrieval that does not require user vision shall be provided,..." ensures that our goals are met in context, namely that it doesn't require user vision.

Otherwise I assure you we will have vendors and lawyers in a room asserting they met the 1194.21(a) and want to get paid, when their solution clearly didn't meet our functional requirements.

While I will agree that "...or support for assistive technology used by people who are blind or visually impaired shall be provided" can be used to the detriment of accessibility (e.g., I develop a program that *requires* an ancient version of a screen reader or a horribly expensive proprietary screen reader that only I, the vendor, sells to work with our specific software) it does allow contracting officers to evaluate through evaluation or demonstration, if a solution is accessible. Beyond explicitly stating and defining what specific assistive technology is allowed, I think this does not prevent contracting officers from exercising their right to common sense or intellect and selecting a current, usable in the current IT environment, and fair value assessment of assistive technology used by the vendors during demonstration. The USPS has specific assistive technologies we require and evaluate vendor compliance based on our organization's technical standards.

So I'd say there is a dependency, a strong must-have dependency hierarchy which can be demonstrated by (in our example software accessibility technical standards) meeting specific subpart B technical standards, where functional performance criteria must also be met.

I hope I didn't miss your point but welcome direct communication if I'm not getting your ideas and you want to clue me in off-list.

Regards,


Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service
phone: 202.268.8246

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Phill Jenkins
Sent: Monday, June 04, 2007 4:56 PM
To: TEITAC General Interface Accessibility Subcommittee
Subject: [teitac-general] Applicability of Functional Performance Criteria



Some of the discussions during the call today and especially the examples seem to be incorrectly founded in the premise that the functional performance criteria provisions always need to be applied. There were several examples or scenarios of Web, Kiosks, and other applications that went something like this:
"The Software and Web provisions already apply here, so why do we need to also apply this "functional criteria" if we already meet all those Software & Web provisions? Shouldn't the functional performance criteria only apply when choosing not to comply with the applicable software and web provisions for a software or web application?

If we took the view of only applying the functional performance criteria when not choosing to comply with the other applicable provisions, then we wouldn't be discussing the "AT used by people with disabilities" clause. If there are some other necessary provisions, then lets discuss them. But if we continue to promote this "catch all" provision as also applying, we will continue to have this unproductive discussion. Why can't we just propose to "drop" the clause that the functional performance criteria also include AT - why not just propose that the functional performance criteria only apply when AT is not provided and the application or product shall be operable without additional AT for users who are blind?

Regards,
Phill Jenkins, (512) 838-4517
IBM Research - Human Ability & Accessibility Center
http://www.ibm.com/able

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