Thread Subject: some general items for discussion
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From: Hoffman, Allen
Date: Thu, Nov 09 2006 10:45 AM
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I just wanted to post these as I'm thinking of them during the meeting
1. I feel that back-office exception can be improved by clarifying some
specific situations where it does not apply, and some where it does.
I'd also consider asking the question, what is the rationale for the
back office exception, e.g. why are people with disabilities excluded
form maintenance work?
2. I believe the biometric standard in 1194.25 should be addressed
directly in the fundamental alteration exception language. I will try
and provide further helpful information about these soon.
3. I feel that national security exception is actually fairly well
defined, but is almost always less-than-well understood. Some
explanatory information on the origins of this might be a helpful
addition in subpart a.
4. I feel that the commercial nonavailability "condition" should be
supplemented by the same requirement for providing the information or
data via an alternate means as is in the undue burden portion. This
would close a loop hole if you ask me.
5. I think that more clear applicability/inapplicability conditions can
be defined for content accessibility. For example, for when
spreadsheets are used, is accessibility a fundamental alteration for
that? When document formats beyond HTML are utilized, how can clear
exceptions and applicability be defined so that it isn't such a big
question. I am thinking currently that a minimum accessibility level
for encoding schemes should be considered, and then used, for example,
information which is encoded in formats other than HTML must be provided
in a format that meets (reference standards) for formats.
6. I think the incidental to a contract exception is sufficient and
does not require change at this time.
7. I think that equivalent facilitation is sufficiently well defined at
this time, but explanatory "guidance" might be helpful.
8. finally, I think that applicability could be improved by including a
sequence for how to apply the standards and exceptions. This would go a
long way towards making implementations more consistent, and improve
over all understanding of how the standards are intended to be used.
That is probably enough for one post.
DHS : CRCL & OCIO;
DHS Office On Accessible Systems and Technology
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