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

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From: Randy Marsden
Date: Fri, Oct 26 2007 11:15 PM

Peter:

I see both sides of the problem and, like you and everyone else, am
trying to find a workable compromise.

The point of my post was that some (me included) find the Access
Board's preamble confusing.

-Randy
ATIA


On Oct 26, 2007, at 4:35 PM, Peter Korn wrote:

> 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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