Thread Subject: Re: was FAQ info and URL; now "Process"

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From: terry.weaver@gsa.gov
Date: Fri, Aug 17 2007 2:25 PM

However, we do strongly suggest to agencies to validate claims made in a VPAT by at least asking for documentation that supports the assertions made on the VPAT. Requesting information such as that is line with the FAR but unfortunately not addressed currently. I want us to remedy that in the FAR update that will follow the refreshed standard.


----- Original Message -----
From: "Gregg Vanderheiden" [ = EMAIL ADDRESS REMOVED = ]
Sent: 08/17/2007 01:53 PM EST
To: "'TEITAC Subpart A Subcommittee'" < = EMAIL ADDRESS REMOVED = >
Subject: Re: [teitac-subparta] [teitac-general] was FAQ info and URL; now "Process"



Yes

This is correct. (

The issue isn't that companies have a process but that they would have to
document their process of making things accessible and report that
externally.

And the access board decided that documenting a process isn't what was
important. Having accessible products come out the far end was.

In the general group discussions there was unanimous voice to not bring the
255 process provisions over to 508.


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



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Jim Tobias
> Sent: Friday, August 17, 2007 12:53 PM
> To: 'TEITAC Subpart A Subcommittee'
> Cc: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] [teitac-general] was FAQ info
> and URL;now "Process"
>
> Not that any of this will result in provisions, but I think
> there is a fundamental misunderstanding here.
>
> Gregg wrote:
> > I don't think you want to go back to 255 process provisions.
> > That would entail companies having to document the process
> that they
> > went through.
>
> I'm not aware of any company that addresses accessibility
> without using a process of some sort, and all of them
> document that process.
> The question is, do they have to reveal that documentation at
> any point?
>
> > The Access-Board (I believe wisely) has take the stance
> that companies
> > should be able to use what process they want as long as the
> outcome is
> > accessible.
>
> No one is trying to force fit a particular process. I think
> we'd be comfortable with an ISO-9000 type approach, which
> lets the enterprise create it own process as long as the
> results of that process can be evaluated.
>
> In fact, you could say that the current situation is that
> VPATs are a required part of the process, so it's not
> entirely new to propose something else along the same lines.
> Many stakeholders are not satisfied with the VPAT, and for
> good reason, in my opinion.
>
> > And the process isn't
> > really that important if the product isn't. it doesn't help people
> > with disabilities.
>
> Look at it another way: there are surely some processes that
> are more effective at resulting in accessible products, such
> as ones that look at competing accessible products, or do
> certain kinds of AT testing, or consult with users with
> disabilities, or provide certain kinds of staff training. At
> the end of the day, none of these guarantees accessibility,
> but it's illogical to assume that there is no connection
> between process and product. When Trace evaluates a new
> product for accessibility, doesn't it proceed according to a
> process built up over years of experience? We need to use
> the scarce mental capital we have in the most efficient
> manner, and expertise about accessibility is pretty darn scarce.
>
> Looked at another way, "accessibility" is a new or different
> way of thinking about products, so it's an innovation. The
> literature on adoption of innovations points to the tendency
> of organizations to innovate by bureaucratizing. They really
> can't get up to speed on something new without nailing down
> who's gonna do what, and where the innovation fits into the
> org chart and the client contact report and the market
> analysis readout, etc.
>
>

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