Thread Subject: Re: FW: FAQ on FPC

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From: Salaets, Ken
Date: Wed, Nov 14 2007 5:55 AM

Hi Gregg. What problem with the current 508 standards are we trying to fix here? Based on the record to date, I am not aware of any particular flaw in the current standards - incuding their utilization by government purchasing and requiring officials - that requires the Access Board to endeavor to create a mandate, i.e., the "musts" and "shalls." I can appreciate that there may be a perception of issues or genuine concern, but I don't recall a presentation documenting specific problems that have resulted in the government failing to provide accessible tools.

Mandating testing of the FPC would be a pretty significant expansion of 508 - and possibly the Board's authority under the law. The cost would also be significant. Without specific evidence that the "system is broken" and that mandatory testing of the FPC is the only solution (an extrapolation, perhaps, of your wiki proposal), I think that it would be difficult for the committee to support this.

Regards,

Ken


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Sent: Tue Nov 13 21:30:57 2007
Subject: Re: [teitac-committee] FW: FAQ on FPC

Thanks Mike,



This is in keeping with what was proposed today. The FAQ says âIf there are applicable provisions in Subpart B that fully address the product or service being procured, then the agency need not look to Subpart C.â

However â it does not say how one would go about determining if âprovisions in Subpart B that fully address the product or service being procuredâ The only way that we were able to determine if the subpart B provisions fully addressed the product were to check the product using Subpart C to see if the technical provisions did indeed cover the product functionality. And the 508 standard specifically says that subpart C is to be used for overall product evaluation. So I think we have a circular reference here. One more thing to make clear.


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.









"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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