Thread Subject: Re: First Responder Exception

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From: Mark D. Urban
Date: Mon, Oct 08 2007 8:10 AM

While I'm normally a passive observer of these discussions, I'd like to make
a point in this regard - as CDC is mentioned.



One of the outcomes of Katrina was an understanding that public health
situations disproportionately affect persons with disabilities. Thus, it is
actually MORE important to have accessible EIT deployed during these times.
Additionally, many volunteer staff have some disabilities, and thus the
accessibility of the internal EIT can also affect the response capability.



HHS (CDC is a division of HHS) generally considers emergency communication
and IT infrastructure accessibility to be an essential mission requirement,
and exceptions are generally not allowed except in pre-documented
circumstances (we have some Commercial non-availability documentation for
certain laboratory and medical EIT). As Norm points out, most materials are
purchased off pre-set blanket purchase agreements (BPAs), rather than being
purchased "on the fly". This allows accessibility review of the EIT
involved in a formal, deliberative way.



I would discourage any consideration of a "First Responder" exception,
except maybe in a limited way such as "purchased incidental to an emergency
response for immediate use only by trained public safety staff".



Regards,



Mark D. Urban

HHS Section 508 Project Manager

919-395-8513

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From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom Brett
Sent: Friday, October 05, 2007 3:46 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] First Responder Exception



Norm said

"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."



I believe that the CDC would need to be excepted from the 508 provision on
purchasing conformant EIT in the event of a serious disease outbreak.
Requiring an agency to perform market research or to search for other
general exceptions would not be in its best interest. Once an agency
determines that the EIT is to be used for the First Responder they should
not have to go any further.



I would also see other civilian agencies, EPA, USPS, Interior, requiring EIT
to insure for the safety of their employees in the event of an emergency
action.





Tom Brett



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