Thread Subject: Re: Clarification of electronic content
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From: Diane Golden
Date: Tue, Feb 19 2008 10:05 AM
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States have voiced very similar concerns about implementation. Robert's
proposed wording may be the best we can do to clarify yet not set up false
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[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Baker,
Sent: Tuesday, February 19, 2008 7:15 AM
To: TEITAC Committee
Subject: [teitac-committee] Clarification of electronic content
Revised proposed language for clarification of electronic content. This
builds on Andi Snow Weaver's proposal and Diane Golden's edits. This is
response to the Access Board's request for clarity on the applicability
of the electronic content provisions to agency content.
In complying with this subpart each agency must ensure that official
electronic communications from the agency comply with the applicable
provisions in the Section 508 standard (in particular the provisions in
subpart C, section 3) when it is readily achievable based on existing
technology, and when it is provided to the public or there is a
reasonable expectation it will be shared with unknown recipients,
regardless of the medium of transmission or distribution. Official
electronic communications may include agency websites, policies or
procedures for employees that are distributed via internal agency
e-mail, electronic newsletters, tutorials that are distributed on CDs,
etc. In complying with this subpart, official electronic
communications would not include legacy content stored for reference or
archiving, or content distributed by third parties that is not
authorized by the agency.
While the intent of this revised definition is to scope the
applicability to something that can be achieved, I still have major
concerns about implementation. With procurement, development, and web
publication there usually is some form of an approval process or life
cycle that can be modified to introduce a compliance process at the
agency level. Other forms of electronic content are more likely
distributed on a less formal basis (for example - personal emails), and
there is no conceivable way to define an agency-wide compliance
monitoring process that would capture all applicable content before it
is released. Furthermore, technology has not matured to the point where
this type of monitoring can be fully automated for all types of
electronic content. Therefore, language such as "readily achievable"
(borrowed from 255), may be what's needed here to temper expectations.
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