Thread Subject: Re: intro for 8.1?

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From: Sean Hayes
Date: Mon, Sep 24 2007 3:30 AM

Peter, I think your observations are valid in the context of office documents, but when we examine the wider scope of what the term "content format" covers I think we find problems.

It might be a valid tactic for an agency trying to meet 508 to voluntarily reduce their complexity burden by standardising on a specific set of technologies like OS, AT and office document types, however as you say that is out of the scope of 508. And even if so the agency would still need to be able to interoperate with content and systems outside of their control, as well as ensuring that the content which is created actually uses the accessibility features.

I agree that the group has done some good work on identifying the kind of information software needs to be able to obtain when using a content format in order to meet the operational provisions, but as I have already stated, it is not always appropriate to include that information directly in the content itself.

I'm not necessarily against recording the groups guidance somewhere but I think there are a number of problems with recording it as specific provisions within 508.

For one, there is the harmonisation problem, no other international standard has such provisions (possibly for the reasons I outline below), and that procurement applies to software and not content formats.

Then there is the issue that federal agencies between them record terabytes of information each year, including digital photographs; satellite imagery; cctv traffic, security, and other video; medical scans; geographical information and so on. These are all recorded in content formats which would not meet the proposed provisions on their own. Even if the agencies could employ the armies of operators it would require to create the descriptions, captions and annotations to make this information accessible; for practical, legal and forensic reasons, any such additional information would likely be entered into a media management database of some sort, not by altering the original content formats.

The proposed content rules while applicable in some specific cases, such as office document creation, do not encompass situations where the information is distributed over a set of content formats, such as HTML and PNG, or DV and timed text files. They also do not accommodate situations where data must necessarily live in an inaccessible format for some period and would be made accessible by later processing, like capturing a digital photograph.

So since the content provisions are already captured in a more general way by the provisions on software, and do not create the same operational constraints, I think we might be able to move the proposed content provisions into notes or guidance materials for the specific software provisions they relate to.

We also need to think about how the software rules apply to tools which are used in the conversion of inaccessible recorded media such as photographs and video, we may need to craft some specific exceptions otherwise we may inadvertently prevent the agencies from procuring tools such as Photoshop which are commonly used in the process of making such materials accessible.

Sean Hayes
Incubation Lab
Accessibility Business Unit
Microsoft

Office: +44 118 909 5867,
Mobile: +44 7875 091385


-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Peter Korn
Sent: 22 September 2007 17:37
To: TEITAC Web/Software Subcommittee
Subject: Re: [teitac-websoftware] intro for 8.1?

Hi Sean,

I think it is true that today few if any U.S. Federal Government
agencies "procure" formats. But we have certainly seen several U.S.
States looking to formally standardize on document formats (cf.
Massachusetts). Likewise we have seen this in a number of European
countries. And I believe the U.S. Library of Congress and other
archiving organizations have been looking at like standardization.

As standardization is different from procurement, it may be that the
vehicle of Section 508 is not the right vehicle for this. But it seems
clear to me that an enumeration of the accessibility information that
must be "preservable" in/with a document format is an entirely
appropriate thing to write down, so that organizations that are looking
to standardize on some number of document formats know what they must
look for to ensure accessibility information is preservable in that format.

And I think this subcommittee has done a very nice job of doing that in
this collection of provisions.


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

> Sorry, I was working from the Sept 3 draft.
>
> One logical problem, if the primary leverage applied by agencies is procurement, is that the agency does not typically procure formats. It procures tools that generate and consume data encoded in those formats or maybe data encoded in formats.
>
> The content rules might be replaced by a blanket clause:
> "Agencies and their employees and agents must ensure electronic information is developed and maintained such that any receiving party can use software to access that information in a manner which complies with the software provisions."
>
> Sean Hayes
> Incubation Lab
> Accessibility Business Unit
> Microsoft
>
> Office: +44 118 909 5867,
> Mobile: +44 7875 091385
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim Tobias
> Sent: 22 September 2007 13:13
> To: 'TEITAC Web/Software Subcommittee'
> Subject: Re: [teitac-websoftware] intro for 8.1?
>
> Thanks.
>
> The first numbers you cite -- are those the 8.1 and 8.2 provisions? So "1"
> is actually 8.1-A in the September 14 draft?
>
> If that's the case, I still argue that although in a perfect world only the
> final product should need evaluation, we are so far from that perfect world
> that upstream provisions are still necessary. At the agency level they
> prevent mischief during use, and at the industry level they support the
> development and marketing of better tools. I don't see how they're overly
> burdensome to either party. For example, we're not insisting that agencies
> purchase tools that use the *most* accessible formats, nor are we imposing
> oversight on format development itself.
>
> If there were no lead paint, there would be no lead painted toys.
>
> ***
> Jim Tobias
> Inclusive Technologies
> +1.732.441.0831 v/tty
> +1.908.907.2387 mobile
> skype jimtobias
>
>
>
>> -----Original Message-----
>> From: Sean Hayes [mailto: = EMAIL ADDRESS REMOVED = ]
>> Sent: Saturday, September 22, 2007 7:53 AM
>> To: TEITAC Web/Software Subcommittee
>> Subject: Re: [teitac-websoftware] intro for 8.1?
>>
>> 1 - covered by 3C
>>
>> 2 - covered by 6 A,B&C
>>
>> 4 - covered by 3K
>>
>> 5,6 & 7 - covered by 3N
>>
>> 8 - covered by 3M
>>
>> 9 - covered by 3C
>>
>> 10 - covered by a combination of 3N and 3C.
>>
>> Sean Hayes
>> Incubation Lab
>> Accessibility Business Unit
>> Microsoft
>>
>> Office: +44 118 909 5867,
>> Mobile: +44 7875 091385
>>
>>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
>> Of Jim Tobias
>> Sent: 22 September 2007 12:42
>> To: 'TEITAC Web/Software Subcommittee'
>> Subject: Re: [teitac-websoftware] intro for 8.1?
>>
>> Sorry -- can you point to the specific provision(s) that
>> would have the effect you claim? I'm not seeing it.
>>
>> ***
>> Jim Tobias
>> Inclusive Technologies
>> +1.732.441.0831 v/tty
>> +1.908.907.2387 mobile
>> skype jimtobias
>>
>>
>>

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