Thread Subject: Re: Suggested update to 6.1.I so we can remove6.1.B and 6.1.C (forms & scripting)
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From: Hoffman, Allen
Date: Wed, Jun 06 2007 3:55 PM
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In the current standard? Sure they are! You can debate whether PDF
forms are a 1194.21 or 1194.22 item, but currently 21(d) would cover PDF
This applies to the software and to HTML, but isn't explicitly
applicable to other content formats. This is exactly why people are
just applying as they can without direct standard to rely upon.
How does this sound for a requirement for content that isn't covered by
software and web or a/v requirements?
title: Electronic content minimum requirements
Electronic content shall be provided in at least one format that meets
minimum format accessibility standards from (format accessibility
standards), and is authored to meet applicable standards from subparts
(b and C).
Non-html electronic content includes, but is not limited to, forms,
text documents, text and graphics documents, charts, flow charts,
organization charts, spreadsheets, presentations, images, sounds,
drawings, diagrams, and maps. To meet this provision electronic content
must be stored in a format that meets the minimum accessibility
requirements from (reference here), and must be authored to be
accessible for each of the applicable provisions the format supports.
For example, if the content includes images, and the format supports
images, the format must include the ability to provide a text
description of the image, and that description must be included in the
content. Note, authoring tools must allow for adding the text
description as well.
Electronic content can be stored in many formats. Specific requirements
are included in the standard for web-based formats such as HTML, and for
software interfaces, and for audio/video content. No specific direct
requirement to make other formats accessible is included in the standard
presently leaving applicability for such formats in a gray area, relying
often only on functional performance criteria. Inclusion of a direct
requirement to make additional content accessible will improve
consistent application of the standard across the board.
Inclusion simultaneously of minimum format accessibility provisions, and
authoring tool provisions as well will provide clear direction to meet
Economic impact: Significant
Costs: Explicitly addressing all electronic content, not just web and
audio/video content increases the scope of Section 508 dramatically in a
clear fashion. The audience this provision would affect is very large,
but numerous efforts are already underway to address this continuing
accessibility challenge both within and externally to the Federal
providing clear standards for electronic content as a whole will lead to
more systematic solutions that can allow for creation of accessible
content from the ground up as opposed to an add-on only at the web
distribution points. Including accessibility as part of regular content
development processes and technologies, people with disabilities will
have greater access to content as a rule rather than an exception to the
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