Thread Subject: Re: FAQ info and URL

Note

This archival content is maintained by WebAIM and NCDAE on behalf of TEITAC and the U.S. Access Board . Additional details on the updates to section 508 and section 255 can be found at the Access Board web site.

From: Gregg Vanderheiden
Date: Fri, Aug 17 2007 10:10 AM

> 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?


That is a good question. The answer is no. The FPC were designed to
provide the overall guidance. The technical were designed to provide
specific guidance where specific or more detailed guidance was desired.

The technical were never conceived as being comprehensive. Hence the FPC.


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



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Diane Golden
> Sent: Thursday, August 16, 2007 6:44 PM
> To: 'TEITAC Subpart A Subcommittee'; 'TEITAC General
> Interface Accessibility Subcommittee'
> Subject: Re: [teitac-subparta] [teitac-general] FAQ info and URL
>
> 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.
>
>

WebAIM is an initiative of:
Center for Persons with Disabilities (CPD) Utah State University