Thread Subject: Re: FAQ info and URL

Note

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From: Diane Golden
Date: Thu, Aug 16 2007 5:35 PM

So I'll ask the obvious question -- weren't the existing technical standards
(and the current draft revisions) developed to "fully address" the
accessibility of a particular product or service? If there are issues not
addressed in the technical standards, shouldn't additional technical
requirements be developed rather than relying on functional requirements to
fill the gap? Obviously not set of standards is ever going to address every
possible access issue or need - but it seemed in both the original
development and this current revision that the goal was for the technical
standards to be comprehensive.

Unfortunately, application of the functional standards in a procurement
requires highly subjective judgments which must be made without the benefit
of standardized, valid, reliable measurment protocols which renders those
judgements extremely difficult to defend, especially in a legal action. (I
just spent the day with my procurement folks and got more than an earful
about the functional performance standards . . . ) They are wonderful
design guidelines and to use Peter's teminology could be "aspirational" for
EIT products, but to include them as a core, mandatory requirement in a
procurement is very difficult.

Diane Golden
NASCIO

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Gregg
Vanderheiden
Sent: Thursday, August 16, 2007 5:30 PM
To: 'TEITAC General Interface Accessibility Subcommittee'; 'TEITAC Subpart A
Subcommittee'
Subject: Re: [teitac-subparta] [teitac-general] FAQ info and URL


Interesting point Allen.

Another example of this was touch screens. In current 508 you can meet all
the technical provisions for a phone and create one with no physical
buttons - just a touch screen. (not 255 but 508)

Of course it would not pass FPC. But if one felt that technical would
obviate FPC then one might conclude that meeting the technical provisions
would equate to automatically meeting the FPC.

The interesting thing is the words "fully address the product or service
being procured". Clearly in both your case and the case above, they
technical provisions did not fully address the product. There were aspects
of the product that affected accessibility that were not covered by the
technical provisions.

Interestingly, the only easy way I know of to determine if the technical
provisions "fully address the product or service being procured" is to apply
the technical provisions to a product and then check the product or design
against the functional performance criteria.

Does anyone know of any other way for people to determine if the technical
provisions "fully address the product or service being procured"?

It would seem that the statement
If there are applicable provisions in Subpart B that fully address the
product or service being procured, then the agency need not look to Subpart
C.
is easy to misread as
If there are applicable provisions in Subpart B that address the product
or service being procured, then the agency need not look to Subpart C.

We need to provide guidance on how to test whether the technical (subpart B)
fully address the product or whether the FPC (Subpart C) are actually
required in the process somewhere.



Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.





From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Hoffman, Allen
Sent: Thursday, August 16, 2007 3:15 PM
To: TEITAC General Interface Accessibility Subcommittee
Subject: Re: [teitac-general] FAQ info and URL
let me document my interpretation here, and if folks concur, then i concur
with this language.

For web sites or applications, almost all agree keyboard accessibility is
required, but not listed currently in the 1194.22 provisions. This would
indicate to me that functional performance criteria must be used until
keyboard access is part of the "applicable" provisions.

If there are applicable provisions in Subpart B that fully address the
product or service being procured, then the agency need not look to Subpart
C.

My basic logic for considering FPC(s) applicable always is that they are
related to the disability, not the EIT, and the disabilities, except when
specifically contra-indicated by fundamental alteration, are not changed for
technical reasons of product selection. I think saying that part C is fully
dependent upon technical adherence to part B just doesn't reflect the
complicated world we live in.




Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303





From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Baker, Robert
C.
Sent: Thursday, August 16, 2007 3:02 PM
To: TEITAC General Interface Accessibility Subcommittee
Subject: Re: [teitac-general] FAQ info and URL
I would concur - "provided that a fundamental alteration would not be
required to meet the FPC." Thank you for taking the leadership to provide
clarity to the FPC language.

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