Thread Subject: Re: intro for 8.1?

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: Katie Haritos-Shea
Date: Tue, Sep 25 2007 9:00 AM

I Strongly agree with Allen

Katie

-----Original Message-----
>From: "Hoffman, Allen" < = EMAIL ADDRESS REMOVED = >
>Sent: Sep 24, 2007 8:15 AM
>To: TEITAC Web/Software Subcommittee < = EMAIL ADDRESS REMOVED = >
>Subject: Re: [teitac-websoftware] intro for 8.1?
>
>Procurement applies to information and data.
>information and data are delivered in some format.
>
>So, for example, I buy a credit reporting service which provides daily
>reports in IDF (inaccessible document format), and another vendor offers
>that information in (adf), accessible document format. Now, you might
>infer section 3 applies, but almost nobody will in the acquisition side
>of things. Without this being an explicitly described item it will, and
>has gotten lost and overlooked.
>
>I think there certainly may be some scoping tweaking that would help,
>but as one who as strived desperately over the past many years to
>improve the accessibility of content, delivered by various software
>mechanisms, I can say this link is what is missing and sorely requires
>some strong mechanism to fix it. Much of the Access-Board's initial
>question of how does Section 508 apply to "content" is based around
>exactly this problem in the end. We have addressed the problem only in
>the surface fashion if we leave out the format portion, and history
>demonstrates that that approach doesn't work. if there is an interim
>mechanism we can use I'd be all for exploring it.
>
>
>
>
>
>
>Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303
>
>-----Original Message-----
>From: = EMAIL ADDRESS REMOVED =
>[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Sean
>Hayes
>Sent: Monday, September 24, 2007 5:25 AM
>To: TEITAC Web/Software Subcommittee
>Subject: Re: [teitac-websoftware] intro for 8.1?
>
>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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