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Thread Subject: Clarifying "without known accessibility needs" - Action Item from 2-26-08 Plenary

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From: Rex Lint
Date: Wed, Feb 27 2008 11:40 AM
Subject: Clarifying "without known accessibility needs" - Action Item from 2-26-08 Plenary

Whitney,

RE your request to clarify my comments concering " without known
accessibility needs" in 2-D

2-D - Accessible Content (Consensed)
This provision is not relevant to the Section 255
guidelines, because it creates obligations for federal agencies
Agencies must ensure that electronic content used for
official agency communications complies with the applicable provisions in
the Section 508 standard (in particular the provisions in Subpart C, Section
3), regardless of the medium of transmission or distribution. An exception
to this provision may be made when content is distributed only to a small
group of recipients without known accessibility needs, or when content is
being stored for archival purposes only.
Note 1: Official agency communications include, but are not
limited to, agency websites, policies or procedures for employees that are
distributed via internal agency e-mail, electronic newsletters, tutorials
that are distributed on CDs and other electronic media.
Note 2: Agencies must make archival content available in an
accessible format upon request.

â��An exception to this provision may be made when content is distributed only
to a small group of recipients without known accessibility needsâ�¦â��
The phrase â��without known accessibility needsâ�� can be interpreted multiple
ways:
* You can distribute the content to a group of recipients if you do
not know their accessiblity needs.
* You can distribute to a group that you know does not have
accessiblity needs.
Iâ��d suggest changing it to:
â��An exception to this provision may be made when content is distributed only
to a small group of recipients known to be without accessibility needsâ�¦â�� or
possibly,

â��An exception to this provision may be made when content is distributed only
to a small group of recipients and accomodates their accessibility needsâ�¦â��
which shifts the meaning a little.

-Rex-

Rex Lint, Consultant
26 Brek Drive
Merrimack, NH 03054
PH: 603-860-7651

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From: Diane Golden
Date: Wed, Feb 27 2008 2:55 PM
Subject: Re: Clarifying "without known accessibility needs" -Action Item from 2-26-08 Plenary

Clarifying "without known accessibility needs" - Action Item from 2-26-08
PlenaryThe second suggested wording seems clearer to me -
â��An exception to this provision may be made when content is distributed only
to a small group of recipients and accomodates their accessibility needsâ�¦â��

Diane Golden

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Rex Lint
Sent: Wednesday, February 27, 2008 12:36 PM
To: 'Whitney Quesenbery'
Cc: 'TEITAC Committee'
Subject: [teitac-committee] Clarifying "without known accessibility
needs" -Action Item from 2-26-08 Plenary

Whitney,

RE your request to clarify my comments concering " without known
accessibility needs" in 2-D

2-D - Accessible Content (Consensed)

This provision is not relevant to the Section 255 guidelines, because it
creates obligations for federal agencies

Agencies must ensure that electronic content used for official agency
communications complies with the applicable provisions in the Section 508
standard (in particular the provisions in Subpart C, Section 3), regardless
of the medium of transmission or distribution. An exception to this
provision may be made when content is distributed only to a small group of
recipients without known accessibility needs, or when content is being
stored for archival purposes only.

Note 1: Official agency communications include, but are not limited to,
agency websites, policies or procedures for employees that are distributed
via internal agency e-mail, electronic newsletters, tutorials that are
distributed on CDs and other electronic media.

Note 2: Agencies must make archival content available in an accessible
format upon request.

â��An exception to this provision may be made when content is distributed only
to a small group of recipients without known accessibility needsâ�¦â��

The phrase â��without known accessibility needsâ�� can be interpreted multiple
ways:

Â· You can distribute the content to a group of recipients if you do
not know their accessiblity needs.

Â· You can distribute to a group that you know does not have
accessiblity needs.

Iâ��d suggest changing it to:

â��An exception to this provision may be made when content is distributed only
to a small group of recipients known to be without accessibility needsâ�¦â�� or
possibly,

â��An exception to this provision may be made when content is distributed only
to a small group of recipients and accomodates their accessibility needsâ�¦â��
which shifts the meaning a little.

-Rex-

Rex Lint, Consultant

26 Brek Drive

Merrimack, NH 03054

PH: 603-860-7651

No virus found in this outgoing message.
Checked by AVG Free Edition.
Version: 7.5.516 / Virus Database: 269.21.1/1301 - Release Date: 2/27/2008
8:35 AM

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From: Whitney Quesenbery
Date: Wed, Feb 27 2008 3:25 PM
Subject: Re: Clarifying "without known accessibility needs" -Action Item from 2-26-08 Plenary

<html>
<body>
The intent (as I understood it) was to reflect situations in which
content was distributed among a known group of individuals, with the
understanding that they would know the specific accessibility needs of
the members of this group. 
So, my EWG suggestion is: 
"An exception to this provision may be made when content is
distributed only to a small group of known recipients and accommodates
their accessibility needs..." 
Whitney 
At 05:14 PM 2/27/2008, Mazrui, Susan K. (formerly Palmer) wrote: 
<blockquote type=cite class=cite cite="">
I believe the intent is to cover
communications among small groups where the none of the participants are
known to have a disability and, I assume,  have not made any
requests for alternate
media.  
  
How about - 
?An exception to this provision may be
made when electronic content is distributed only to a small group of
recipients without disabilities.? 
  
Is this too simple? 
Susan 
  
 
Susan Mazrui 
 
Director, Federal
Regulatory 
 
AT&T Services,
Inc. 
 
1120 20th Street,
N.W., Suite 1000 
 
Washington,
DC  200036 
 

<a href="mailto: = EMAIL ADDRESS REMOVED = "> = EMAIL ADDRESS REMOVED = </a> 
 
(202) 457- 2056
office 
 
(703) 973-5220
mobile 
 
  
 
This e-mail
and any files transmitted with it are the property of AT&T, are
confidential and are intended solely for the use of the individual or
entity to whom this e-mail is addressed. If you are not one of the named
recipient(s) or otherwise have reason to believe that you have received
this message in error, please notify the sender at [202-457-2056] and
delete this message immediately from your computer. Any other use,
retention, dissemination, forwarding, printing, or copying of this e-mail
is strictly prohibited. 
<hr>
<div align="center"></div>
From:
= EMAIL ADDRESS REMOVED =
[<a href="mailto: = EMAIL ADDRESS REMOVED = " eudora="autourl">
mailto: = EMAIL ADDRESS REMOVED = </a>] On Behalf Of
Diane Golden 
Sent: Wednesday, February 27, 2008 5:00 PM 
To: 'TEITAC Committee'; 'Whitney Quesenbery' 
Subject: Re: [teitac-committee] Clarifying "without known
accessibilityneeds" -Action Item from 2-26-08 Plenary 
  
The second suggested wording seems
clearer to me - 
?An exception to this provision may be
made when content is distributed only to a small group of recipients and
accomodates their accessibility needs?? 
  
Diane Golden 
  
 -----Original Message----- 
From: = EMAIL ADDRESS REMOVED =
[<a href="mailto: = EMAIL ADDRESS REMOVED = " eudora="autourl">
mailto: = EMAIL ADDRESS REMOVED = </a>]On Behalf Of
Rex Lint 
Sent: Wednesday, February 27, 2008 12:36 PM 
To: 'Whitney Quesenbery' 
Cc: 'TEITAC Committee' 
Subject: [teitac-committee] Clarifying "without known
accessibility needs" -Action Item from 2-26-08 Plenary 
 
Whitney, 
 
RE your request to clarify my comments
concering " without known accessibility needs" in 2-D 
 
2-D - Accessible Content (Consensed) 
 
This provision is not relevant to the
Section 255 guidelines, because it creates obligations for federal
agencies 
 
Agencies must ensure that electronic content
used for official agency communications complies with the applicable
provisions in the Section 508 standard (in particular the provisions in
Subpart C, Section 3), regardless of the medium of transmission or
distribution. An exception to this provision may be made when content is
distributed only to a small group of recipients without known
accessibility needs, or when content is being stored for archival
purposes only. 
 
Note 1: Official agency communications include,
but are not limited to, agency websites, policies or procedures for
employees that are distributed via internal agency e-mail, electronic
newsletters, tutorials that are distributed on CDs and other electronic
media. 
 
Note 2: Agencies must make archival content
available in an accessible format upon request. 
 
?An exception to this provision may be made
when content is distributed only to a small group of recipients without
known accessibility needs?? 
 
The phrase ?without known accessibility needs?
can be interpreted multiple ways: 
 
Â·
     
 You can distribute the content to a
group of recipients if you do not know their accessiblity needs. 
 
Â·
     
 You can distribute to a group that you
know does not have accessiblity needs. 
 
I?d suggest changing it to: 
 
?An exception to this provision may be made
when content is distributed only to a small group of recipients known to
be without accessibility needs?? or possibly, 
 
?An exception to this provision may be made
when content is distributed only to a small group of recipients and
accomodates their accessibility needs?? which shifts the meaning a
little. 
 
    -Rex- 
 
Rex Lint, Consultant 
 
     26 Brek
Drive 
 
     Merrimack, NH
03054 
 
     
PH:    603-860-7651     
  
 
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outgoing message. 
Checked by AVG Free Edition. 
Version: 7.5.516 / Virus Database: 269.21.1/1301 - Release Date:
2/27/2008 8:35 AM 
  </blockquote>
<x-sigsep></x-sigsep>
 
Whitney Quesenbery 
= EMAIL ADDRESS REMOVED = 
phone: 908-638-5467 
mobile: 908-328-5959  
<a href="http://www.wqusability.com/" eudora="autourl">
www.WQusability.com 
</a><a href="http://www.usabilityprofessionals.org/" eudora="autourl">
www.usabilityprofessionals.org</a>  
"You create complexity by layering simplicity" - Jean
Erdman</body>
</html>

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From: Gregg Vanderheiden
Date: Wed, Feb 27 2008 3:30 PM
Subject: Re: Clarifying "without known accessibility needs" -Action Item from 2-26-08 Plenary

Interesting

I think both of these are improvements.

The first says - you know that there are none. This is the most
straightforward.

The second one though gives you more freedom. If there are people who DO
have disabilities and you accommodate them - you still can ignore (the rest
of) the 508 guidelines.

So I'm happy with either but I think the second one is better. It requires
less than the other but still requires all that is needed.

A fixed typo and 1 word change to make it flow better yields:

"An exception to this provision may be made when content is distributed only
to a small group of recipients that accommodates their accessibility needs.

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

_____

From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Rex Lint
Sent: Wednesday, February 27, 2008 12:36 PM
To: 'Whitney Quesenbery'
Cc: 'TEITAC Committee'
Subject: [teitac-committee] Clarifying "without known accessibility needs"
-Action Item from 2-26-08 Plenary

Whitney,

RE your request to clarify my comments concering " without known
accessibility needs" in 2-D

2-D - Accessible Content (Consensed)

This provision is not relevant to the Section 255 guidelines, because it
creates obligations for federal agencies

Agencies must ensure that electronic content used for official agency
communications complies with the applicable provisions in the Section 508
standard (in particular the provisions in Subpart C, Section 3), regardless
of the medium of transmission or distribution. An exception to this
provision may be made when content is distributed only to a small group of
recipients without known accessibility needs, or when content is being
stored for archival purposes only.

Note 1: Official agency communications include, but are not limited to,
agency websites, policies or procedures for employees that are distributed
via internal agency e-mail, electronic newsletters, tutorials that are
distributed on CDs and other electronic media.

Note 2: Agencies must make archival content available in an accessible
format upon request.

"An exception to this provision may be made when content is distributed only
to a small group of recipients without known accessibility needs."

The phrase "without known accessibility needs" can be interpreted multiple
ways:

* You can distribute the content to a group of recipients if you do
not know their accessiblity needs.

* You can distribute to a group that you know does not have
accessiblity needs.

I'd suggest changing it to:

"An exception to this provision may be made when content is distributed only
to a small group of recipients known to be without accessibility needs." or
possibly,

"An exception to this provision may be made when content is distributed only
to a small group of recipients and accomodates their accessibility needs."
which shifts the meaning a little.

-Rex-

Rex Lint, Consultant

26 Brek Drive

Merrimack, NH 03054

PH: 603-860-7651

No virus found in this outgoing message.
Checked by AVG Free Edition.
Version: 7.5.516 / Virus Database: 269.21.1/1301 - Release Date: 2/27/2008
8:35 AM

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From: Baker, Robert C.
Date: Thu, Feb 28 2008 4:25 AM
Subject: Re: Clarifying "without known accessibility needs" -Action Item from 2-26-08 Plenary

Susan gets to the point below. The proposed EWG re-wording no longer sounds like an exception.

------------------------------
Robert Baker
Social Security Administration
Section 508 Coordinator
SSA Accessibility Resource Center

Office: 410.966.7602
Email: = EMAIL ADDRESS REMOVED =

Sent by Blackberry
------------------------------

----- Original Message -----
From: = EMAIL ADDRESS REMOVED = < = EMAIL ADDRESS REMOVED = >
To: TEITAC Committee < = EMAIL ADDRESS REMOVED = >
Sent: Wed Feb 27 17:21:40 2008
Subject: Re: [teitac-committee] Clarifying "without known accessibility needs" -Action Item from 2-26-08 Plenary

The intent (as I understood it) was to reflect situations in which content was distributed among a known group of individuals, with the understanding that they would know the specific accessibility needs of the members of this group.

So, my EWG suggestion is:

"An exception to this provision may be made when content is distributed only to a small group of known recipients and accommodates their accessibility needs..."

Whitney

At 05:14 PM 2/27/2008, Mazrui, Susan K. (formerly Palmer) wrote:

I believe the intent is to cover communications among small groups where the none of the participants are known to have a disability and, I assume, have not made any requests for alternate media.

How about -
â��An exception to this provision may be made when electronic content is distributed only to a small group of recipients without disabilities.â��

Is this too simple?
Susan

Susan Mazrui

Director, Federal Regulatory

AT&T Services, Inc.

1120 20th Street, N.W., Suite 1000

Washington, DC 200036

= EMAIL ADDRESS REMOVED =

(202) 457- 2056 office

(703) 973-5220 mobile

This e-mail and any files transmitted with it are the property of AT&T, are confidential and are intended solely for the use of the individual or entity to whom this e-mail is addressed. If you are not one of the named recipient(s) or otherwise have reason to believe that you have received this message in error, please notify the sender at [202-457-2056] and delete this message immediately from your computer. Any other use, retention, dissemination, forwarding, printing, or copying of this e-mail is strictly prohibited.

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From: Whitney Quesenbery
Date: Thu, Feb 28 2008 5:35 AM
Subject: Re: Clarifying "without known accessibility needs" -Action Item from 2-26-08 Plenary

<html>
<body>
I don't understand why meeting a known individual's specific needs is not
an exception. 
Would this be better if it said: 
"An exception to this provision may be made when
content is distributed only to a small group of known recipients and
accommodates their individual accessibility needs..." 
The point here is that it allows for content that meets some of
the requirements, but not necessarily all of them, as long as the people
who must use the content can access it. 
 
At 06:24 AM 2/28/2008, Baker, Robert C. wrote: 
<blockquote type=cite class=cite cite="">Content-class:
urn:content-classes:message 
Content-Type: multipart/alternative;
boundary="----_=_NextPart_001_01C879FC.77C1F825";
x-avg-checked=avg-ok-1D2E3F57 
Susan gets to the point below.  The proposed EWG
re-wording no longer sounds like an exception. 
------------------------------ 
Robert Baker 
Social Security Administration 
Section 508 Coordinator 
SSA Accessibility Resource Center 
Office:  410.966.7602 
Email: = EMAIL ADDRESS REMOVED = 
Sent by Blackberry 
------------------------------ 
----- Original Message ----- 
From: = EMAIL ADDRESS REMOVED =
< = EMAIL ADDRESS REMOVED = > 
To: TEITAC Committee < = EMAIL ADDRESS REMOVED = > 
Sent: Wed Feb 27 17:21:40 2008 
Subject: Re: [teitac-committee] Clarifying "without known
accessibility needs" -Action Item from 2-26-08 Plenary 
The intent (as I understood it) was to reflect situations in which
content was distributed among a known group of individuals, with the
understanding that they would know the specific accessibility needs of
the members of this group. 
So, my EWG suggestion is: 
"An exception to this provision may be made when content is
distributed only to a small group of known recipients and accommodates
their accessibility needs..." 
Whitney 
At 05:14 PM 2/27/2008, Mazrui, Susan K. (formerly Palmer) wrote: 
 
        I believe the intent is to
cover communications among small groups where the none of the
participants are known to have a disability and, I assume,  have not
made any requests for alternate media. 
        
        How about - 
        Ã¢??An exception to this
provision may be made when electronic content is distributed only to a
small group of recipients without disabilities.Ã¢?? 
        
        Is this too simple? 
        Susan 
        
       
        Susan Mazrui 
       
        Director, Federal
Regulatory 
       
        AT&T Services, Inc. 
       
        1120 20th Street, N.W., Suite
1000 
       
        Washington, DC 
200036 
       
        = EMAIL ADDRESS REMOVED = 
       
        (202) 457- 2056 office 
       
        (703) 973-5220 mobile 
       
        
       
        This e-mail and any files
transmitted with it are the property of AT&T, are confidential and
are intended solely for the use of the individual or entity to whom this
e-mail is addressed. If you are not one of the named recipient(s) or
otherwise have reason to believe that you have received this message in
error, please notify the sender at [202-457-2056] and delete this message
immediately from your computer. Any other use, retention, dissemination,
forwarding, printing, or copying of this e-mail is strictly
prohibited.

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From: Hoffman, Allen
Date: Thu, Feb 28 2008 6:30 AM
Subject: Re: Clarifying "without known accessibilityneeds" -Action Item from 2-26-08 Plenary

I don't think we are examining the scenarios right here.

Exceptions are not required for audiences which include people with
disabilities. When someone with a disability that requires information,
it should meet the standards. Selecting which standard to meet for that
particular item based upon the disability is way too much analysis, but
will take place for people who are pragmatic about meeting individual
needs as a reasonable accommodations approach.

The exception is needed when the document or content is destined for a
small known audience of people who may not have any disabilities, and
the content is not intended to be directly migrated to a larger group
who may have disabilities. In this instance, accessibility requirements
are kind of a mute point. No reasonable accommodation is needed for
this situation.

Does this help?

By allowing such an exception we drastically improve this requirement
from being something that may in reality be applicable to all Federal
employees and contractors working for the government, to situations
where the content may actually make its way to someone with a
disability.

In reality, most contractual deliverables would not meet the exception,
and in my view they shouldn't.

In practice agencies would develop policies and procedures to monitor
this, and take actions when needed. They won't be perfect, but what is?

Tools will improve as the need expands. This is the nature of the
standard, to set the bar, and let market forces and work practices do
their jobs. by setting the requirement for a large amount of content,
we are pushing the market forces to see the need.

Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303

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From: Gregg Vanderheiden
Date: Thu, Feb 28 2008 10:55 AM
Subject: Re: Clarifying "without known accessibilityneeds" -Action Item from 2-26-08 Plenary

The short version that Susan suggests will work. But I think it is
unnecessarily narrow.

What if you have a group and it has only one person in the group and they
are deaf. I am send an email to the 4 people and want to include a
picture.

With the EWG wording - I can just include it - since I will have met all the
needs of the users I am sending to.

With Susan's wording (since one is deaf) - I will need to apply the full
508 to it.

I think the EWG wording is better. It invokes all of 508 when you
don't know who will see it. It allows you to pick and choose 508
provisions to meet just the needs of those you are sending to when you know
their needs - without having all of 508 apply

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

_____

From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Baker, Robert
C.
Sent: Thursday, February 28, 2008 5:24 AM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-committee] Clarifying "without known
accessibilityneeds" -Action Item from 2-26-08 Plenary

Susan gets to the point below. The proposed EWG re-wording no longer sounds
like an exception.

------------------------------
Robert Baker
Social Security Administration
Section 508 Coordinator
SSA Accessibility Resource Center

Office: 410.966.7602
Email: = EMAIL ADDRESS REMOVED =

Sent by Blackberry
------------------------------

----- Original Message -----
From: = EMAIL ADDRESS REMOVED =
< = EMAIL ADDRESS REMOVED = >
To: TEITAC Committee < = EMAIL ADDRESS REMOVED = >
Sent: Wed Feb 27 17:21:40 2008
Subject: Re: [teitac-committee] Clarifying "without known accessibility
needs" -Action Item from 2-26-08 Plenary

The intent (as I understood it) was to reflect situations in which content
was distributed among a known group of individuals, with the understanding
that they would know the specific accessibility needs of the members of this
group.

So, my EWG suggestion is:

"An exception to this provision may be made when content is distributed only
to a small group of known recipients and accommodates their accessibility
needs..."

Whitney

At 05:14 PM 2/27/2008, Mazrui, Susan K. (formerly Palmer) wrote:

I believe the intent is to cover communications among small groups
where the none of the participants are known to have a disability and, I
assume, have not made any requests for alternate media.

How about -
"An exception to this provision may be made when electronic content
is distributed only to a small group of recipients without disabilities."

Is this too simple?
Susan

Susan Mazrui

Director, Federal Regulatory

AT&T Services, Inc.

1120 20th Street, N.W., Suite 1000

Washington, DC 200036

= EMAIL ADDRESS REMOVED =

(202) 457- 2056 office

(703) 973-5220 mobile

This e-mail and any files transmitted with it are the property of
AT&T, are confidential and are intended solely for the use of the individual
or entity to whom this e-mail is addressed. If you are not one of the named
recipient(s) or otherwise have reason to believe that you have received this
message in error, please notify the sender at [202-457-2056] and delete this
message immediately from your computer. Any other use, retention,
dissemination, forwarding, printing, or copying of this e-mail is strictly
prohibited.

Previous message |

From: Hoffman, Allen
Date: Thu, Feb 28 2008 12:25 PM
Subject: Re: Clarifying "without known accessibilityneeds" -Action Item from 2-26-08 Plenary

I can live with it but feel its over-complicated and runs a risk of
getting this provision dropped down the line.

Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303

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