Thread Subject: Re: teitac-video Digest, Vol 2, Issue 2

From: Baquis David
Date: Mon, Nov 06 2006 3:58 PM

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I caught a portion of today's AV subcom telecon. There was a lot of
confusion over 508 requirements for audio-visual information. Some of
it was cleared up during the call and via the listserv. Here are some
notes I jotted down during the call that may help:

1.) As Jonathan Hahm said, the TEITAC can recommend changes to the
Standards. That might be inspired by current requirements that you think
are insufficient as well as by concerns with technical assistance you
have heard. You shouldn't feel constrained by current limitations in the
Standards. Instead, you might want to ask if there are areas of
technological discrimination that need to be addressed.

2.) The term "regardless of format" is in the multimedia provisions.
That is important because it means that federal multimedia videos would
be required to be accessible, regardless of whether they are on a
website, VHS tape, DVD, flash drive, server or embedded into an email!

3.) It is correct that the multimedia provisions do not cover single
media. So in the example given, if you have a file that is purely audio,
such as a book on tape, then it is not addressed by 1194.24. It sounded
like that is a gap you would like to see addressed.

4.) If that audio file is on a website, then it is covered. A common
example might be a recording of a radio broadcast, where there is
nothing to see. The driving accessibility requirement is 1194.22(a). The
audio file is considered a non-text element for which a text equivalent
is required. Let's contrast the 3rd and 4th points here. If the audio
file is located in any other media besides the web, such as on a CD,
then it would not currently be covered. Of course, the converse is true
for a file of purely visual information, such as a silent movie on the
web, in which case audio description might be indicated.

Consider that this is related to the overall question of what kind of
type of electronic information is covered, where is it covered, what
standards should apply, etc. You may want to discuss how your
recommendations will sync with those of the web/software subcom that is
also addressing content. Here is what I send them the other day:
http://teitac.org/mailarchives/mail_message.php?id=626&listid=3

5.) Where audio and visual information needs to be synchronized, a
transcript is not acceptable as a means of 508-conformance. I think
there was a question about whether that is clear enough in 1194.24.
There was a suggestion that a definition of captioning be added to
Subpart A.

6.) If there is a voluntary consensus standard for captioning, it would
be helpful as a reference in your recommendations. It might help address
complaints about poor quality captioning (e.g., lag time, errors,
captions block important visual information on screen, etc.). If not,
then you may want to consider developing advisory notes to go along with
recommended requirements.

7.) There was a comment about open or closed captioning of videos. Those
specific terms are used in the current multimedia provision. Right now,
agencies can use either method to provide accessibility.

8.) There was a suggestion that information might be drawn from
complaints. I think that comment pointed in the right direction, but
you're not going to learn much from formal 508 complaints. Instead, I
would like you to consider drawing upon regular conversations you have
had with people about captioning over the past decade. We know that
some of you have populations of hundreds or thousands of people you can
gather comments from.

Let me give you an example. Yesterday someone called me to complain
about a federal agency that hired a company to caption its video posted
on the web. This complaint took the form of a technical assistance
inquiry. The type of the captioning in this case involved highlighting
words on a transcript (to the right of the image) as the dialogue
proceeded. The specific complaint was that the highlight color was a
slight butter shade. It was not strong yellow. He felt like the
usability was so poor that it did not sufficiently meet the spirit of
508. He was not able to follow it very well and cited a reading
disability, not only because of the color but the way it jumped around.
I am sure that some of you can come up with anecdotes on your own. Yes,
it is true that many consumers do not file official complaints, but I
know they do a lot of sharing among others in their networks.

9.) Remember that you can recommend that the Access Board develop
technical assistance materials. You don't need to limit your
recommendations to the actual standards. Would you like to see a
bulletin on ways captioning is provided in videos? For example,
sometimes users can adjust the font color, size, style, etc. Also
consider differences between captions on a live webcast versus a
pre-recorded training video. FYI, you can see examples of Access Board
bulletins on our publications page:
http://www.access-board.gov/pubs.htm.

David Baquis
Accessibility Specialist
U.S. Access Board
1331 F Street, NW, #1000
Washington, DC 20004
800-USA-ABLE; (202) 272-0013 (voice)
www.access-board.gov; = EMAIL ADDRESS REMOVED = "Leading the way to
excellence in accessibility"

"Thank you for your questions concerning section 508 of the
Rehabilitation Act Amendments of 1998. Section 508 authorizes the
Access Board to provide technical assistance to individuals and Federal
departments and agencies concerning the requirements of this section.
This technical assistance is intended solely as informal guidance; it is
not a determination of the legal rights or responsibilities of entities
subject to section 508."


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Sent: Wednesday, November 01, 2006 3:05 PM
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Subject: teitac-video Digest, Vol 2, Issue 2

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Today's Topics:

1. extract from FAQs on www.section508.gov ( = EMAIL ADDRESS REMOVED = )
2. Working on revised c,d,e for 1194.24 (Andrew Kirkpatrick)
3. Re: - participate in revision of Section 508 rule 1194.24
(Karen Peltz Strauss)
4. Hand Raising Utility http://teitac.org/tohru/
(Takemura, Michael (HP Accessibility))
5. Re: Working on revised c,d,e for 1194.24 (Hoffman, Allen)


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Message: 1
Date: Wed, 1 Nov 2006 15:41:54 -0500
From: = EMAIL ADDRESS REMOVED =
Subject: [teitac-video] extract from FAQs on www.section508.gov
To: = EMAIL ADDRESS REMOVED =
Message-ID:

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The section of the FAQs that address captioning:


C.6 Use of EIT in Federal Agency Training
i. If a Federal agency conducts training and uses multimedia, such as
videotapes or computer based training, must the materials developed be
accessible under 508?
Yes. Multimedia is considered EIT and, if used by the Federal
government,
must be accessible unless an exception applies (see sections F and G,
below). Section 1194.22 of the Access Board's standards addresses
requirements for web- based intranet and internet information and
applications. Section 1194.24 addresses video and multimedia products.
In
addition to the requirements of section 508, agencies also have
obligations to their employees under sections 501 and 504 of the
Rehabilitation Act.
ii. If a Federal agency is distributing a television or multimedia
production or a web-cast presentation, does it have to be open or closed

captioned and audio-described?
Section 1194.24(c) and (d) of the Access Board's standards require that
all training or informational video and multimedia productions which
support the agency's mission and which have audio information or visual
information that is necessary for the comprehension of the content, be
captioned or audio described. Hence, if the production is multimedia
(e.g.
image and sound) and is considered "training or informational," then it
must meet the applicable requirements of 1194.24 (c) and (d) of the
Access
Board's standards. If the production is web-based, regardless of whether

it is multimedia, such as a live webcast of a speech, then it must also
meet the applicable requirements of 1194.22.
iii. Does the requirement to open or close caption and audio describe
apply to productions that have a limited purpose, scope, and shelf life
or
contain quickly "perishable" information?
Section 1194.22 of the Access Board standards applies requirements to
web-based intranet and internet information and applications without
regard to the perishable nature of a production. Similarly, section
1194.24 addresses video and multimedia products without regard to the
shelf life of a production.
iv. Do videotapes of briefings or "raw or stock" film footage for
documentation purposes have to be captioned or audio described? What if
the videotape is later played for an audience? Do graphs and charts used

in the briefing have to be audio described?
Briefings or other recordings made for purposes of documentation are not

considered "training or informational videos." As noted in the preamble
to
the Access Board's final rule, section 1194.24 does not require that a
videotape recorded by a field investigator to document a safety
violation
be captioned or audio described. However, if such a videotape were
subsequently used as part of a training or informational presentation,
it
would have to be captioned and audio described. (See 65 Federal Register

80517, December 21, 2000.) Any graphs or charts that are not described
in
the narration of the video would have to be audio described if the
visual
information was necessary for the comprehension of the content.
v. Is the requirement to open or close caption, and to provide audio
description specific to English?
No. The requirement to caption (i.e., to provide access to audio
information for persons with hearing impairments) and provide audio
description applies irrespective of the language. It is recommended that

captioning and audio description be in the same language as the content
of
the production. For example, Spanish audio should be captioned in
Spanish.
There is no requirement to provide captioning in a language different
from
the content of the production (e.g., English audio need not be in
Spanish
or vice versa.) vi. Must the lyrics in songs embedded in productions be
open or closed captioned?
This answer depends on whether the lyrics are considered content
essential
for comprehension. For instance, a production that features a dialogue
between two people while a radio softly plays a song in the background
should have the conversation in the foreground captioned. However, since

the song from the radio is not essential for comprehension, the captions

could simply indicate that music is playing in the background.
C.7. "Agency Websites"
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Message: 2
Date: Wed, 1 Nov 2006 12:53:06 -0800
From: "Andrew Kirkpatrick" < = EMAIL ADDRESS REMOVED = >
Subject: [teitac-video] Working on revised c,d,e for 1194.24
To: "TEITAC Audio/Video Subcommittee" < = EMAIL ADDRESS REMOVED = >
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< = EMAIL ADDRESS REMOVED = >
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I'm going to work on a new version of 1194.24.c,d,and e. Anyone
interested in working on this and then sharing with the subcommittee,
please reply to this message.

Thanks,
AWK

Andrew Kirkpatrick
Corporate Accessibility Engineering Lead
Adobe Systems
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Message: 3
Date: Wed, 1 Nov 2006 15:54:14 -0500
From: "Karen Peltz Strauss" < = EMAIL ADDRESS REMOVED = >
Subject: Re: [teitac-video] - participate in revision of Section 508
rule 1194.24
To: "TEITAC Audio/Video Subcommittee" < = EMAIL ADDRESS REMOVED = >
Message-ID: <023501c6fdf7$e3c00700$9865fea9@PELTZSTRAUSS>
Content-Type: text/plain; charset="iso-8859-1"

I would like to be part of the group to revise 1194.24 (c), (d), and
(e). And I propose that Larry Goldberg also be part of this effort.

Karen Peltz Strauss
= EMAIL ADDRESS REMOVED =
----- Original Message -----
From: Brett, Thomas F
To: = EMAIL ADDRESS REMOVED =
Sent: Wednesday, November 01, 2006 9:47 AM
Subject: [teitac-video] (no subject)


For your consideration, I would like to suggest that a couple of items
be added to this sub committee web site to facilitate the
teleconferences. I copied 1 & 2 below from the General Subcommittee
site...3 & 4 are of my own design...



Please let me know if you have additions or comments to these items.





1. All communications are accessible and use accessible tools

2. All participants agree to communications, postings etc that are
courteous and constructive.



* Comments restricted to topics, ideas or other opinions

* Do not make comments about other people or organizations.



3. For the purpose of closed captioning



* Please identify yourself prior to starting your comments or
questions.

* Please do not talk over someone.

* If you are using Acronyms please spell them out



4. Utilize the Hand Raising Utility.





Tom Brett,

Section 508 Coordinator

US Office of Personnel Management

Rm 6H34A

2026061206 (v)

2026062582 (tty)

Disabled does not mean Unable

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