Thread Subject: Re: AT and IT interoperability - the regime we are operating under today

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From: Peter Korn
Date: Fri, Oct 26 2007 4:40 PM

Hi Randy,

I'm sorry, I just don't read this text the way you appear to be reading it.

> The problem is the statement issued by the Access Board is ambiguous.
> The single sentence quoted by Peter appears to suggest that an IT
> manufacturer doesn't need to be aware of the "AT universe".

The sentence is: "Manufacturers do not need to be aware of the universe
of assistive technology products on the market.". There is no "appears
to suggest" in this sentence. It is quite explicit.

> However, if you read the entire paragraph, the last sentence seems to
> suggest the opposite: that "there are numerous resources available to
> manufacturers to assist them in identifying specific types of
> assistive technology which would be used with their product".
> Clearly, that sentence indicates some level of responsibility for the
> manufacturer to get educated about what AT exists for their
> product(s). So, I don't agree with Peter that it is clear what is
> meant - especially when considering the entire directive.

Sorry, again I just disagree. When the government tells me as a citizen
that there are numerous tax preparers who can assist me fill out my
taxes, they aren't placing a responsibility on me to use them, to get
educated about them, or to do anything with them. You are making a
significant logic leap from a non-normative preamble to a responsibility
placed on manufacturers - especially in a document that regulates
agencies and NOT E&IT manufacturers.

> Bruce - I feel the directive issued by the Access Board contains
> statements that can be viewed as conflicting, and is part of what has
> led to the lack of consensus on this point.

Randy - separate from any interpretations of Access Board writings on
this matter - I'd like to know what *your* opinion is on this matter.
You have made it mostly pretty clear that you don't feel 508 should
require anything of acquired AT (please speak up if I have this wrong).
Do you feel that 508 should require agencies to only purchase E&IT that
has been guaranteed by the E&IT vendor to work AT? (with one AT
product? one per category? all AT? what?).


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

>
> Randy Marsden
> ATIA
>
>
>
> On Oct 26, 2007, at 1:56 PM, Peter Korn wrote:
>
>> Hi Bruce,
>>
>> Thank you very much for this clarification. From this, it seems clear
>> that the regime we are operating under today (as set by the Access Board
>> in the quote Bruce provided to us) is that E&IT manufacturers are not
>> expected to "be aware of the universe of AT", and that by supporting the
>> specific provisions in 1194.21 relating to any given AT, E&IT vendors
>> are understood to be satisfying the functional performance criteria.
>>
>> Therefore, any and all work we do - in specifying the rich set of
>> information E&IT must provide to AT as we have done in 3-U, and in
>> setting forth platform requirements as we have done in 3-V and elsewhere
>> - is an improvement over the current regime and in no way a step
>> backward from what the Access Board expected would be the case.
>>
>>
>> Certainly this still leaves open the question of whether our drafts "go
>> far enough"; but I believe it closes the question of whether our drafts
>> "go backward" in any way. They do not.
>>
>>
>> Regards,
>>
>> Peter Korn
>> Accessibility Architect,
>> Sun Microsystems, Inc.
>>
>>> Responding to Peter's question posted to list:
>>> http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1
>>> <http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1>
>>>
>>> The Access Board is eager for TEITAC to advise on this concern. If
>>> there is not a single consensus position, multiple recommendations
>>> are welcomed. The Access Board has already addressed this issue as
>>> best we can in the preamble to the 508 rulemaking:
>>>
>>> <begin quote>
>>>
>>> Comment. The ITIC requested clarification as to how a manufacturer
>>> would determine the type and number of assistive technology devices
>>> for which support must be provided by a product.
>>>
>>> Response. Manufacturers do not need to be aware of the universe of
>>> assistive technology products on the market. Each provision
>>> specifies the type of assistive technology that must be supported.
>>> For example, §1194.31(a) addresses those assistive technology
>>> devices which provide output to persons who cannot see the screen.
>>> Such devices may include screen readers, Braille displays and speech
>>> synthesizers. There are numerous resources available to
>>> manufacturers to assist them in identifying specific types of
>>> assistive technology which would be used to access their product.
>>>
>>> Paragraph (a) provides that at least one mode of operation and
>>> information retrieval that does not require user vision shall be
>>> provided, or support for assistive technology used by people who are
>>> blind or visually impaired shall be provided. It is not expected
>>> that every software program will be self-voicing or have its own
>>> built-in screen reader. Software that complies with §1194.21 would
>>> also satisfy this provision. (See §1194.27(a) in the NPRM.) No
>>> substantive comments were received regarding this provision and no
>>> changes were made in the final rule.
>>>
>>> <end quote>
>>>
>>> http://www.access-board.gov/sec508/preamble.htm
>>>

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