Documentation:Alternate Format

Documentation > Alternate Format

Is the current 508 text clear on who supplies alternate format (who pays for it).

This page contains the discussion of this issue. For current drafts, please see: the current drafts on the main Documentation Subcommittee page

The draft history has also been preserved

The following topic was added to draft #1 submitted to the TEITAC co-chairs on March 12, 2007.

Item to be raised with the Access Board: Is it possible or appropriate to ensuring that any training or technical support provided accommodates the functional capabilities of all participants and provides meaningful support.

This can include not only:Accessibility needs of individuals with disabilities (as participants or trainers); and Means of communicating with individuals with disabilities before and after training; but also commonly used adaptive technology used with the manufacturers and provider's E&ITs; and Solutions for accessibility and compatibility.

Responses to the initial email.

Comment from Dawn Wilcox on January 11, 2007:

I interpret 1194.41 (a) to mean the manufacturer provides it and pays for it. but we could make it more obvious by adding - the manufacturer pays for and the agency requests alternate formats.

Comment from Tom Brett on January 11, 2007:

I agree that the standard should explicitly state that the manufacturer pays for the alternate format.

Comment from Norman Robinson on January 12, 2007:

I'll disagree!

The Section 508 technical standard shouldn't mandate the burden applies to the vendor. The agency procuring should have language that covers their business needs. I would expect the smart vendor would readily agree to "pay for the alternate format" by structuring a fee or charge for each event. I would expect vendors who plan might have absorbed this cost to fund it elsewhere through their contracting agreement. I think it certainly would harm small vendors who didn't contractually prepare for such an event and damage our business relationship.

Certainly, it could be easier to "make" the vendors give us the alternate when our agency didn't include the right contracting language, but that is a bad approach in my opinion. We'd be better off stating each agency must consider specific language identifying the requirement for alternate formats. In a perfect world we'd all agree on what that format was and included it in the refresh - be it HTML, DAISY, or whatever format is appropriate in a perfect world.

Comment from Debbie Cook on January 11, 2007:

I think that providing alternative formats is an accommodation responsibility of the gency. And, I think there re types of requests for alternate formats which may go beyond htose we traditionally think of particularly when it comes to cognitive accommodation. But, having said all that, I do believe the manufacturer has the obligation to create environments where alternative formats can be readily produced. So I think a requirement more that that for text books where the manufacturer has to provide digital formats is more appropriate and probably more likely to go through than expecting every manufacturer to produce the variants of alternative format that might be requested.

Comment from Barbara Lybarger on January 12, 2007:

The bottom line is that alternative formats must be available. Depending on the actual set of parties involved it varies which one is in the best position to produce the a particular format. What about leaving it open as a point of negotiation, with the agency ultimately responsible that the alternative formats be produced as needed and the vendor obliged to at minium provide digital copy that can be used to do the formating?

Comment from Mike Fratkin on January 12, 2007:

I concur with this approach that as a minimum the vendor be required to supply an electronic version. However, I would add that this electronic version must be in an accessible format. We have required this in the past which has met with mixed results as vendors do not seem to understand what "accessible format" means so there probably needs to be some additional guidance. Agencies should not have to be responsible for interpreting what the alt text, for example, should be for images or screen shots. Agencies should not have to be responsible for properly tagging PDF documents.

Comment from Jim Tobias on January 12, 2007:

First, I'm not sure that we can require that the vendor provide anything -- the whole burden of 508 falls directly on the agency; it's the agency's responsibility to require the vendor to meet the standards. So that means that the agency has to include accessible documentation in its RFP and contract language. At least, that's how I understand it....

Second, I think we can do a better job of specifying how to meet this need if we start with a few general principles:

1. To use Mike's example, agencies shouldn't have to tag PDF files provided by a vendor. It's reasonable to require tagged PDF and any other accessible format the agency prefers, such as HTML or ASCII or whatever. The principle here is that the vendor is closer to this part of the responsibility, since they are the "publisher".

2. It may not be reasonable to require vendors to provide braille manuals, since they may not have braille production facilities. Agencies -- especially those agencies that employ blind people who use braille -- are closer to this part of the responsibility in that they may already have braille production facilities. The vendor, however, should provide the documentation in such a form that it can be readily brailled without much additional effort. So if the vendor provides a file of the documentation pre-formatted for braille, and the agency takes that file and produces a braille document, that seems like a good balance.

3. Certain other related functions may fit better on the vendor side, especially pagination (for both braille and large print) and a text description of all images where the information does not already appear in the text of the documentation.

Comment from David Baquis on January 12, 2007:

Access Board's response:

No, the 508 Standard does not specify who creates and pays for it. The standard falls on the shoulders of federal agencies to provide it (the product support documentation in alternative formats) if requested.

A best practice might be for an agency experienced in this subject to request, in their RFP, an electronic convertible version of the product support documentation. The TEITAC may consider recommending an advisory note on this subject.

Remember that you can recommend lots of advisory notes. Your recommendations, needn't be limited to changes in the actual standards and guidelines.

Next, remember that you are providing recommendations for both 255 and 508. These laws address documentation differently, and both subjects could be addressed in your discussions. 255 requires the telecom manufacturers to provide their product support documentation in alternative formats at no additional charge if requested.

Therefore, in connecting these dots, if I were a federal agency specifically buying a telecom product, I would expect the telecom manufacturer to already be up to speed on this subject and would inquire how they are meeting their 255 documentation requirement.

You can't have a requirement in the 508 standards that tells manufacturers what to do. That reflects confusion about 508. 508 is a purchasing requirement, not a production requirement.

Comment from Jim Tobias on January 12, 2007:

This issue seems to me to be one of those that is just outside the scope of the standards, but one which TEITAC might well comment on for the sake of improving implementation. That is, perhaps we cannot require agencies to require accessible documentation from vendors, but we *can* suggest several best practices that will allow agencies to meet their accessible documentation responsibilities.

Comment from Terry Weaver on January 12, 2007:

In support of David's comments above, the Buy Accessible Wizard and the training provided by GSA all tell government buyers that they should require all electronic documentation delivered under the contract to meet the web provisions under the Standards. This is a current government best practice; I am including a sample below of suggested RFP language:

All reports and deliverables provided in electronic media shall be accessible to people with disabilities in accordance with the relevant accessibility standards (see below) referenced in Section 508 of the Rehabilitation Act (29 U.S.C. 794d), as amended by the Workforce Investment Act of 1998 (P.L. 105-220), August 7, 1998.

1194.22 Web-based Intranet and Internet Information and Applications

1194.31 Functional Performance Criteria

1194.41 Information, Documentation, and Support

Comment from Norman Robinson on January 12, 2007:

I'll second that it is the _agency_ that Section 508 applies to and we contract our vendors to provide services that support our requirements (that include Section 508 provisions).

We have specific language we try to use that I'll share in case the example helps clarify:

1.0 Section 508 Compliance

Section 508 is a legal requirement that requires federal agencies, including the USPS, to procure Electronic and Information Technology (EIT) that is accessible to persons with disabilities. Section 508 establishes technical and functional standards that eliminate the barriers in electronic technology and information.

Contractors must ensure the electronic products and information delivered are accessible. Please refer to Section X.X.X, Accessibility Requirements and Section X.X.X, Standards & Guidelines, handbooks USPS AS-508 Section 508 & USPS AS-508-A Section 508 Technical Reference Guide.

2.0 Maintenance and Support Requirements

To support the implementation of the Supplier solution, the supplier will provide all system and training documentation in electronic format acceptable to create new documentation in alternate formats. Our target format is (X)HTML and use with a standards compliant web-browser. [NOTE: Contracting officer should consider having technical staff verify content can be easily created in HTML when a proprietary file format is desired].

Note that we try to make the language as plain and simple as possible for vendors to understand, assuming they don't have knowledge of Section 508. However we do typically provide references to the law in our own guidance (AS-508 & AS-508-A) but feel vendors respond better to _OUR_ requirements than to what may seem to be an obscure legal reference. We have other supporting requirements in our template language but this is the one relevant to 1194.41(a) "Alternate Formats".

Comment from Greg Pisocky on January 22, 2007:

I favor an approach where vendors provide documentation in an electronic format that would enable the agency to produce . The vendor can reasonably be expected to provide the necessary documentation in a format that enables the agency to produce the required deliverables in whatever alternate formats and quantities the agency requires- but at the agency's cost in terms of consumables (paper), labor (transcription services), and other associated production and distribution costs associated with getting these materials into the hands of the individuals needing them.

Indeed, the agency is in a better position to determine what the alternative formats should be and in what quantities. It would be an undue burden on the vendor to attempt to anticipate all of the necessary formats an agency might require. Vendors can provide the raw material, the agency must be responsible for the finished product.

Additional questions:

None raised at this time.