Thread Subject: Re: FAQ info and URL

Note

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From: Phill Jenkins
Date: Thu, Aug 16 2007 3:35 PM

Allen,
I agree a web application should be keyboard accessible. And I interpret
1194.22 (L)'s provision about "functional text" as requiring keyboard
access. And I think the 508 Refresh is addressing wording in the
provisions so keyboard access is more explicit for Web.

However, my interpretation of "fully address the product or service" is
different than yours. Since there is an 1194.22 that specifically
addresses Web-based intranet and internet information and applications,
and your example is a web site, then 1194.22 fully addresses your product
or service unless there is some other part of your product or service that
needs to be addressed. If 1194.21, 1194.23, or 1194.24, etc. (the other
sections of SubPart B) don't address your product fully, then the
functional performance criteria (Sub-Part C) come into play. In other
words, the FPC was not covering holes in the technical provisions, but in
the applicability of sub-part B for products or services that didn't fully
fit into the existing sections of technical provisions in Sub-Part B:

Subpart B -- Technical Standards
§ 1194.21 Software applications and operating systems.
§ 1194.22 Web-based intranet and internet information and applications.
§ 1194.23 Telecommunications products.
§ 1194.24 Video and multimedia products.
§ 1194.25 Self contained, closed products.
§ 1194.26 Desktop and portable computers.
§ 1194.26 Desktop and portable computers.

I also think my interpretation is in line with the preamble text that
says:
"Paragraph (a) provides that at least one mode of operation and
information retrieval that does not require user vision shall be provided,
or support for assistive technology used by people who are blind or
visually impaired shall be provided. It is not expected that every
software program will be self-voicing or have its own built-in screen
reader. Software that complies with §1194.21 would also satisfy this
provision."

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

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