Thread Subject: Re: "Content" in our subcommittee
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From: Baquis David
Date: Mon, Oct 30 2006 2:55 PM
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The question of whether "a Word document attached to an email is
covered" does not sufficiently capture the breadth of what the Access
Board needs recommendations on. So let me try to lay it out:
Question #1: Is electronic content covered under 508?
Both the statute and the Standard say that Section 508 addresses
"information and data". What does that mean? It seems to suggest that
Section 508 does not just address technology. Do you think that any of
the current provisions in the 508 Standard cover content? Do you believe
that the web provisions are really "technology" provisions (as opposed
to content provisions) because the web is considered a piece of
technology and that is why it is covered? (Note that web is specifically
given as an example in the definition of E&IT). Do you think it is
confusion that what seems like content to some, can be viewed as
technology to others? Certainly, I think it can be clarified that we are
talking about electronic content, not just any content. So the Committee
needs to deliberate on the yes or no question of whether it was the
intention of the law to address accessibility of electronic content.
Related to that, we strongly need information on the potential economic
impact of such a determination. It is best if the Access Board is not
left on its own to try to figure this out after the Committee disbands,
as that might result in an overestimate. It is important that the
Committee understands that this economic impact information could make a
difference in whether this or any other recommendation makes it into the
final rule. Many advocates would like to see clear requirements
covering electronic content. Others outside the world of accessibility,
however, worry about whether it is "do-able" to impose such a
requirement on the huge volume of government electronic content.
2.) Question #2: If electronic content is covered under 508, then what
kind of information and data is covered?
* Some people have remarked that they think the current standards
are geared toward a specific type of code (HTML). What do you think and
do you have a recommendation related to whether they should go beyond
* Does electronic content include various documents, such as PDF,
wordprocessed, spreadsheet, database, presentation shows, etc?
* Does electronic content include email? Does that mean both
web-based email as well as "regular" email (for lack of a better word).
3.) Question #3: Assuming that you determine that electronic content is
covered and you discern the types of information and data that are
covered, does it matter where the electronic content resides?
* Must the content reside on a website in order for 508 provisions
to apply to it?
* To ask that another way, if the content does not reside on a
website, does that mean that 508 does not require it to be accessible?
* What if a document resides on a server? Sometimes the server is
accessed via an office intranet, but does that matter to you in the
determination of whether it is covered under 508?
* What about FTP files?
* What if the document is on a CD, flash drive or other item that
* What if the document is on your own computer, but not
distributed to anyone? Might that be considered "pre-decisional" or
sort of like "raw footage"?
4.) Question #4: Having pushed through the issues of whether electronic
is covered, what type of content is covered, and how location of the
content might affect the determination of coverage, there is still
another outstanding matter: What actual design requirements are
necessary to ensure accessibility of electronic content?
You might imagine documents when answering this, but remember that
documents are not the only kind of electronic content. This is a
frequently asked question: "Can you tell me what to do to ensure that my
PDF document meets 508?" Are the current 508 standards woefully short in
electronic content provisions?
* Are there existing voluntary consensus standards that can be
referenced in the updated 508 standards? (Adobe > Isn't there work on
developing one for PDFs? - And if so, what is the estimated completion
* What do you think about 1194.22(a) being used to justify why
PDFs are covered. Do you think that is a stretch? Is that provision
really meant for things like photos and illustrations?
* Tables, maps and eletronic forms are specifically mentioned in
the current standards. What else might a robust set of standards for
electronic content address?
* A frequently asked question is: "What should I write in the alt
tag?" Would the Committee like to tackle the art of determining
sufficiency in text equivalents for non-text elements? Maybe this could
at least be an advisory note?
* E-learning generates serious complaints. Is the problem simply
that the 508 standards are fine but companies are not just implementing
them? Or might the problem also be that there is a need to add or change
some requirements in order to address learning management systems and
e-courses? It is this second question that we are concerned with. Given
the government's increased use of e-training, it is important to get
this right and contact all the necessary experts you can think of to
make sure you didn't miss anything.
* Logical reading order is an example of a specific issue that
some people think needs to be addressed in the refreshed standards. That
might be an example of how a usability issue gets reframed as an
accessibility issue? How can be this be address through an enforceable
requirement? Isn't the term "logical" arbitrary? Is there a voluntary
consensus standard on this that can be referenced? Of course, before
discussing this, you should first decide whether electronic content is
covered under 508.
* By the way, have you considered that this issue could end up
being applied to 255? Has the Committee seen a demonstration of how a
website could be used by all employees to control settings for their
VoIP telephone system? Do you want to handle this jointly with the
telecom subcommittee, instead of deferring it?
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From: Jim Tobias [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Thursday, October 26, 2006 8:15 AM
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Cc: Creagan Tim; Capozzi David; Baquis David ; Bailey Bruce
Subject: "Content" in our subcommittee
The Group B wiki page does a great job of pulling out the provisions in
and 22 that address content (rather than navigation or operation). But
not sure if it hits the issue presented to us by the Access Board. If I
remember correctly, they had gotten a lot of questions about whether
documents attached to email, like a Word file with an image, was covered
508 and if so, did they require some other sort of technical solution.
1. Am I right in stating your concern, Access Board folks?
2. Is Group B on the right track for that concern?
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