Thread Subject: Re: "Content" in our subcommittee

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From: Brett, Thomas F
Date: Wed, Nov 01 2006 8:45 AM

> I agree 100% with Mike and Allan. I myself have not heard a credible

>argument in favor of excluding content from 508. Can someone please
make

>such an argument, or point us to one?



A couple of thoughts regarding the laws dealing with Section 508...



* 1194.1 states in part "...access to and use of information and
data ..."

* it is generally understood that the definition of EIT in
Section 508 derives its definition from the Clinger - Cohen Act. The OMB
interpretation of Clinger-Cohen in Appendix IV to OMB Circular No A-130
would support that content should be included in the standards. The
following link is supplied in support of including content as part of
the Section 508 guidance:
http://www.whitehouse.gov/omb/circulars/a130/a130appendix_iv.html



which states:



The definition of "government information" includes information created,
collected, processed, disseminated, or disposed of both by and for the
Federal Government. This recognizes the increasingly distributed nature
of information in electronic environments.



Tom Brett,

Section 508 Coordinator

US Office of Personnel Management

Rm 6H34A

2026061206 (v)

2026062582 (tty)

Disabled does not mean Unable

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-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim
Tobias
Sent: Wednesday, November 01, 2006 10:17 AM
To: 'TEITAC Web/Software Subcommittee'
Subject: Re: [teitac-websoftware] "Content" in our subcommittee



> The entire" is content included" debate has people with

> considerable knowledge and experience in the field really

> split from my experience.

> Personally I can't see how content is not included, but well

> informed others concluded it was not the intent to include

> content, but rather the delivery mechanisms. I just never

> thought that made a lot of sense to require that you be given

> inaccessible information--what would be the point of doing so."

>

> I concur completely with Allen that it makes no sense to be

> given inaccessible information whether it is from an e-mail

> or from a tool. It may have been the intent originally of

> Section 508 to only address the delivery mechanism, but the

> content should be considered at this time.

>

> It seems to make little sense to spend resources to test an

> interface for a viewer, the tool to produce electronic forms,

> the player or learning management system for electronic

> learning, and terminal emulators that display mainframe

> applications and then ignore the content which is typically

> the most important element.



I agree 100% with Mike and Allan. I myself have not heard a credible

argument in favor of excluding content from 508. Can someone please
make

such an argument, or point us to one?



I think that this issue arises from a confusion about roles. In brief,
I

think it may be industry saying "We can make tools that allow, and even

promote, the creation of accessible content, but maybe we cannot make
tools

that disallow the creation of inaccessible content." I agree with this

statement -- you can't blame the car manufacturer for people driving too

fast. The "drivers" are the federal workforce, and they are responsible
for

the actual accessibility of the content.



The "handoff" in this accessibility value chain could certainly be
argued.

Do tools have to provide contextual help, as in "I see you're pasting an

image into this document. You may be required to add a text
description.

Would you like to do that now?" Instead, should federal employees
receive

tool-based training on creating accessible content? Regardless of what
the

decisions are, there does need to be an assignment or understanding of

overall shared responsibility.

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