Thread Subject: Re: intro to 8.1
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From: Hoffman, Allen
Date: Wed, Sep 26 2007 10:15 AM
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Currently there is considerable lack of clarity about what the
provisions in 8.1 were intended to be for, and how they might be used if
kept in the recommendations. Beyond this, is a lack of consensus on if
inclusion of such provisions is the best approach to improve
accessibility of information.
Once consensus was achieved that web and software user-interface
provisions should be combined, the question still outstanding was how to
handle "content", to address the Access-board's initial theme of
clarifying how Section 508 should apply to content not only on
"websites". Consensus was achieved that content beyond web-based HTMl
content did need to be covered and addressed.
Original standards contain such "format" specific instructions as "use
of alt or longdesc attributes", for web based information. Clearly the
previous standards addressed specific ways to meet the standards for
"some" content types and formats, but did not address any beyond HTML.
This has lead to much confusion as to how such provisions are to apply
to various information presented through user-interfaces.
Currently Section 3 addresses user-interfaces and content, while section
6 addresses audio/video content and playback interfaces. While
user-interfaces do not have to depend upon content to operate, think
about applications which manage logins, or allow user-control of
equipment, etc, most applications are dependent upon content, and are
the connection between the content and the human interaction.
Web-browsers depend upon the content, and specifically the formats of
that content to be rendered for the end-user. Word processors are
dependent upon the content and the format of the content to produce
information from the end-user. Sections 3 and 6 contain provisions that
address the end-delivered rendering of content, but do not address the
underlying content itself, nor the basic functionality, or capacity of
the underlying content formats themselves. The concept behind the
provisions in 8.1 is to delineate what capacities a content format must
have in order to allow the applications to render that information to
meet the provisions of sections 3 and 6, reliably. Section 8.1
provisions do not address assurance that authors used the capacities of
the content format to achieve the accessibility, but we have added
section 8.2 on authoring tool requirements to promote selection of
applications that allow such authoring to take place.
Currently section 8.1 and sections 3 and 6 are not specifically linked
to ensure that accessible formats are selected, and that those formats
are used to produce content and render it to the end-user to meet the
section 3 and 6 standards.
Some members have voice the opinion that a standard at the
user-interface point is sufficient to ensure that accessibility of
information is achieved, while others contend that both portions of the
information architecture should be addressed by accessibility standards.
To resolve this basic difference of perspective, here are a few
suggested changes we might consider.
1. condense section 8.1 into a single provision with subparts, as the
accessibility services provision is now, and move it to the information,
documentation and support section--which has historically been
determined to be an agency requirement, not a technical requirement.
Add a note to sections 3 and 6 indicating that the items delineated in
this new moved section are critical to successfully meeting
Changes the intended audience of the delineated format metrics to the
agency from the vendor;
Creates the guidance for vendors to rely upon these metrics to meet
May cause the item to be overlooked as it is only one item;
makes formats a pass fail rather than a continuum of accessibility;
2. Eliminate the section 8.1.
Its not needed.
Will lower burden on vendors and agencies;
Will not provide guidance to agencies as to what an accessible format
Probably won't achieve consensus;
3. convert section 8.1 to explanatory/notes material after section 3,
or interspersed with various provisions throughout such as 3-f/8.1-a and
8.1-i, 3-g/8.1-/8.1-k, 3-h/8.1-k, 3-m/8.1-c, 3-o/8.1-cd&e, or after
information/documentation/support. Include specific guidance at top of
section 3 and 6 that these explanatory notes are critical to
successfully meeting these requirements, and that agencies must select
more accessible formats when identifying them to industry as part of a
solicitation or purchase order.
May resolve the objection to these provisions as part of the official
May allow the specific items from 8.1 to be clearly identified as
specific factors when determining a format's level of capacity to
represent information to be rendered in an accessible way;
May devalue the level of attention to use of standard metrics for
formats and format selection;
I feel these three alternative solutions may lead us to consensus about
this important topic, and would like to facilitate coming to consensus
on this as lack of consensus may devalue the recommendation as it moves
Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303
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