Thread Subject: Re: FPCs

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From: Tom Brett
Date: Mon, Oct 08 2007 3:25 AM

A philosophy that has been employed by the more technically astute 508
coordinators is that if the product was developed in accordance with the
technical standards and the AT still would not allow the employee or member
of the public to access the EIT, the most likely problem was with the AT not
with the product.



Still the Government has a responsibility to provide access to the EIT. If
the EIT is inaccessible using the employee's preferred AT, this then becomes
a decision point for the Government manager.does she say find an alternative
or work with the AT vendor and product manufacturer to find a reasonable
solution. In my experience, most managers will take the easy way and look
for an alternative. The alternative can take the form of giving the
employee different job duties that do not require her to access the EIT or
providing different AT. That AT will require additional training and there
could be a learning curve but the Government would be responsible for paying
for that training.



If the product has the capability to work with AT because the manufacturer
has developed the product in accordance with the technical standards and can
demonstrate that the product meets the technical standards then the
manufacturer can say they have met the 508 standards.



The FPC really fall on the Government.not the manufacturer.



Tom Brett



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From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Sunday, October 07, 2007 11:41 PM
To: 'TEITAC General Interface Accessibility Subcommittee'
Subject: Re: [teitac-general] FPCs



As was pointed out by several people, the new 508 technical provisions are
much better than the old ones but are still a long way from being an API. A
better characterization is that they describe the requirements on an API.
Thus it is very possible to meet the current Technical Provision and not
provide access to the functionality of the product.



There is currently a question on the table as to whether a product that has
no AT that works with it - can claim to meet 508 via AT compatibility.



Some feel it should since it isn't the manufactures problem that AT doesn't
work with their product (if there is no known bug in their end)



Others feel that the purpose of 508 is to allow employees of the government
(and the public for public E&IT) to have access to E&IT. that means that
the E&IT is either directly accessible or works with real AT that the people
can get. Otherwise there is no way for them to use the E&IT to do their
jobs.



See discussion page.



I am hoping that we can find a common ground that says that AT must exist.
That lets agencies specify what needs to exist. And that can address the
"it worked a minute ago until they updated the AT" and related problems.




Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.






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From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Phill Jenkins
Sent: Tuesday, September 25, 2007 9:02 AM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-general] FPCs


> I don't understand this.

What part?

> When I say '508' I mean the entire process, everything that applies, not
just the narrow Technical Provisions.
> If we mean 'Technical Provisions', we should say that. I'm trying to
reinforce the reality that the FPCs are *part* of 508.

What do you mean by 'narrow Technical Provisions'? From a software or web
application developer view, they are very comprehensive and inclusive. I
too am trying to reinforce the reality of the FPCs as *part* of 508. And I
believe I do mention and will continue to try to say Technical Provisions
(TPs) when I specifically mean that part of 508.

Do you agree with me that
A product that has only one or more ATs customized for it by the agency
or vendor
instead of meeting the TPs
is not more 508 compliant than a product that meets all of the TPs?


Or are you saying that meeting the FPCs satisfies 508 and trumps not meeting
all the TPs?

When a product requires AT (not self voicing, not self magnifying, etc.),
that is when meeting the TPs should be sufficient, at least from an industry
view when completing a VPAT. Because meeting the TPs is what TEITAC has
defined as supporting AT. So industry is done then and its the agency that
has to provide the AT customization if necessary for meeting the FPCs? Or
are you saying industry is not done and in addition to meeting the TPs they
also have to have the AT customized to meet the FPCs as well?

Products meeting the TPs and then failing to be as usable as desired with a
particular AT (failing to meet the FPCs) happens all the time. Its probably
more often that the product fails to first to even meet the TPs, so industry
is still focused on that half. AT does have a role in completing the
solution. But everyone keeps telling me that 508 doesn't address AT. If it
does - where?

When the product does *not* need AT, that is when the FPCs should be used
because FPCs address the whole solution (including self voicing, self
magnifying, etc.). If you require the FPCs to be used in addition to
meeting the TPs, and there is AT involved, then therein lies the problem.

Regards,
Phill Jenkins
IBM Research - Human Ability & Accessibility Center
http://www.ibm.com/able

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