Thread Subject: Re: First Responder Exception

From: Robinson, Norman B - Washington, DC
Date: Fri, Oct 05 2007 1:30 PM

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I agree with Tom that people will focus on the words "field environment"
and default to an exception without much thought. That certainly has
been my experience with "back office exceptions" over the years.

I would also like to ask why an exception is needed. In the context of
Section 508, if electronic and information technology (E&IT) is
available that meets the technical standards and can be used in the
"field environment", why wouldn't it be beneficial to require
compliance? There are already other general exceptions that apply
(market availability, undue burden, & best meets) so why do we need this
exception? Accessibility doesn't prevent use in any of the field
environment/first responder use scenarios. The only administrative
benefit I could see is to reduce burden when purchasing E&IT in response
to an actual emergency event; the evaluation process for selection of a
product could be at odds with saving lives. Even then, most items are
purchased off blanket contracts and I think requiring compliance where
feasible would be beneficial.

As an aside, I've seen the justification for "field environment" related
as equating to "first-responder" themes. I don't agree as I thought the
reasoning for national security exceptions was one of obscurity. Asking
for compliance documentation of "Super-Secret-Device2000" could
compromise the security of the device and the program using it. But I
suppose it is for the NSA and other agencies to clarify and not for me
to apply my imagination or try and justify it for them.

Regards,


Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service
phone: 202.268.8246

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom Brett
Sent: Friday, October 05, 2007 7:53 AM
To: 'TEITAC Subpart A Subcommittee'
Subject: [teitac-subparta] First Responder Exception



Currently the exception for first responders as shown in the
9/14 EWG is:



This part does not apply to any electronic and information
technology operated by agencies in a field environment where the
function, operation, or use is by a first responder, emergency,
security, or law enforcement personnel. This exception does not apply to
the agency systems administrative and business applications (including
payroll, finance, logistics, and personnel management applications) or
any application or system that is intended for use by members of the
public.



There are many agencies that have a headquarter office and
several field offices. I can see that some people will focus on the
words 'field environment' in the exception and try to apply it only to
field offices. I would think that eliminating those word and worded as
below would remove any confusion.



This part does not apply to any electronic and information
technology operated by agencies where the function, operation, or use
is by a first responder, emergency, security, or law enforcement
personnel. This exception does not apply to the agency systems
administrative and business applications (including payroll, finance,
logistics, and personnel management applications) or any application or
system that is intended for use by members of the public.

Tom Brett

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