Thread Subject: Re: Best Meets vs. Full Use inFunctional PerformanceCriteria
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From: Deborah Buck
Date: Tue, May 01 2007 3:10 PM
Subject: Re: Best Meets vs. Full Use inFunctional PerformanceCriteria
I think it is still premature to say there is support to using "Best Meets". Many are still uncertain what that really means and it appears that at the federal level their is inconsistency is how Best Meets is viewed and implemented across federal agencies. "Best Meets" is not a standard practice at the state level-whereas Best Value is often a required practice in many state procurement laws.
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Date: Tue, 01 May 2007 16:28:52
To:"'TEITAC General Interface Accessibility Subcommittee'"< = EMAIL ADDRESS REMOVED = >
Cc:'TEITAC Subpart A Subcommittee' < = EMAIL ADDRESS REMOVED = >
Subject: [teitac-subparta] Best Meets vs. Full Use in Functional Performance
Criteria
"Best meets" is used by the federal government and some states to determine which products to procure to comply with Section 508 (in cases where there are no products meeting all applicable standards). Â Based on proposals from the Subpart A Subcommittee (See http://teitac.org/wiki/Subpart_A:Application), there is support for using a best meets approach in the next version of the standards.
However, including the term "full use" in the Functional Performance Criteria draft language (1194.31 a, b, c, d, e) appears to be in conflict with this principal.
(http://teitac.org/wiki/General_April_survey-report, http://teitac.org/wiki/RESULTING_DRAFT)
For any E&IT products not able to meet these criteria 100%, the vendor would have to indicate "does not meet" on any 508 documentation, such as the VPAT. Â Therefore, it may be more difficult for agencies to determine which product "best meets" 508 for those product categories where there are no products reaching the 100% bar.
The addition of new accessibility features in products would also not be encouraged unless they allowed full use of the E&IT.  This is discouraging for  manufacturers who have the goal of incorporating new accessibility features over time.
"Full use" is a very high bar. Â For many large office products, none of our users have access to ALL the features. Â Some modes can be accessed by the manufacturer's/dealer's authorized service engineers only for safety purposes. Â For these practical reasons, removing the term "full" is recommended. Â Other alternatives welcome.
Aubrey
Aubrey Woolley
Government Policy and Compliance Analyst
Government Marketing Division
Canon USA, Inc.
TEL: (703) 807-3158
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From: Gregg Vanderheiden
Date: Tue, May 01 2007 10:20 PM
Subject: Re: Best Meets vs. Full Use inFunctional PerformanceCriteria
The "full use" in the functional doesn't conflict with 'best meets'. It is
the same as any other requirement. Fully meets would require that you meet
it. Best meets only requires that you meet them better than other products.
This is the same as any other provision.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
_____
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[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
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Sent: Tuesday, May 01, 2007 3:29 PM
To: 'TEITAC General Interface Accessibility Subcommittee'
Cc: 'TEITAC Subpart A Subcommittee'
Subject: [teitac-subparta] Best Meets vs. Full Use in Functional
PerformanceCriteria
"Best meets" is used by the federal government and some states to determine
which products to procure to comply with Section 508 (in cases where there
are no products meeting all applicable standards). Based on proposals from
the Subpart A Subcommittee (See
http://teitac.org/wiki/Subpart_A:Application), there is support for using a
best meets approach in the next version of the standards.
However, including the term "full use" in the Functional Performance
Criteria draft language (1194.31 a, b, c, d, e) appears to be in conflict
with this principal.
(http://teitac.org/wiki/General_April_survey-report,
http://teitac.org/wiki/RESULTING_DRAFT)
For any E&IT products not able to meet these criteria 100%, the vendor would
have to indicate "does not meet" on any 508 documentation, such as the VPAT.
Therefore, it may be more difficult for agencies to determine which product
"best meets" 508 for those product categories where there are no products
reaching the 100% bar.
The addition of new accessibility features in products would also not be
encouraged unless they allowed full use of the E&IT. This is discouraging
for manufacturers who have the goal of incorporating new accessibility
features over time.
"Full use" is a very high bar. For many large office products, none of our
users have access to ALL the features. Some modes can be accessed by the
manufacturer's/dealer's authorized service engineers only for safety
purposes. For these practical reasons, removing the term "full" is
recommended. Other alternatives welcome.
Aubrey
Aubrey Woolley
Government Policy and Compliance Analyst
Government Marketing Division
Canon USA, Inc.
TEL: (703) 807-3158
= EMAIL ADDRESS REMOVED =
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