Thread Subject: Group B: 22(a)

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From: Hoffman, Allen
Date: Mon, Oct 30 2006 1:55 PM

All:

If this goes under another heading please correct me.

Something to consider when thinking of "missing" topics in web
provisions is the Completely Automated Public Turing test to tell
Computers and Humans Apart, (CAPTCHA) use. I feel this is actually
covered by correct application of 1194.22(a, maybe L, and definitely N),
but that it isn't specific.

Maybe something more direct like:

When Completely Automated Public Turing test to tell Computers and
Humans Apart, (CAPTCHA) techniques are used, functional performance
criteria from 1194.31(a-f) must be met.

or even:

When Completely Automated Public Turing test to tell Computers and
Humans Apart, (CAPTCHA) is used, alternate methods for separating
computers and humans that include people with disabilities must be
provided.

or even:

When Completely Automated Public Turing test to tell Computers and
Humans Apart, (CAPTCHA) is used, CFR1194.22(a), CFR1194.22(b),
CFR1194.22(c), CFR1194.22(l), and CFR1194.22(n), must be met.

or

Up in another section, (subpart a), something might be added saying:

Completely Automated Public Turing test to tell Computers and Humans
Apart, (CAPTCHA), is not to be considered for fundamental alteration or
national security or undue burden exceptions.

I hope this will spark a usable standard.

Allen Hoffman

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