Thread Subject: Re: FPCs

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From: Peter Korn
Date: Thu, Oct 11 2007 11:00 AM

Gregg,

I'm sorry, but I must disagree with your characterization of what "is
true today", and whether what is being discussed is a weakening or not.

In the Functional Performance criteria of the published Section 508 that
we have been living under for some years now - at
http://www.access-board.gov/sec508/standards.htm#Subpart_c - the
language for (a) - (d) are all: "... or support for assistive technology..."

The current language is not "... or must work with assistive technology...".

And I believe that the lack of clarity on what "support" is for AT in
the existing, published document means that by our defining that clearly
in our draft AT-IT interoperability provision means that we are in fact
strengthening section 508 if we otherwise kept the existing published
FPC, making no changes to it.


I understand that even with a detailed description of what "supports"
means is not in and of itself sufficient to guarantee that AT exists and
that AT & IT are in fact working together. I understand that is a
concern and something we are still wrestling with. But I object to the
claim that the current draft work is a weakening. It is, perhaps, an
insufficient strengthening.


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

> That is true today because the test has been that IT must work with
> AT. If we change the rules (weaken them) so that only an API is
> required then testing with AT would no longer be technically required.
> And I think you would find there would be less work with AT vendors
> and then things would change rapidly. This is the primary concern of
> AT vendors and consumers.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
> ------------------------------------------------------------------------
>
> *From:* = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] *On Behalf Of *Tom
> Brett
> *Sent:* Monday, October 08, 2007 4:22 AM
> *To:* 'TEITAC General Interface Accessibility Subcommittee'
> *Subject:* Re: [teitac-general] FPCs
>
> 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
>
> ------------------------------------------------------------------------
>
> *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.
>
> ------------------------------------------------------------------------
>
> *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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