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Early Drafts for Subpart D

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Subpart D -- Information, Documentation, and Support

§ 1194.41 Information, documentation, and support.

This version was as of March 16, 2007

(a) To enable Federal agencies to provide product support documentation to end-users in an accessible format, Federal agencies shall require that all documentation supporting the product, including but not limited to reports, system documentation and end user training or technical support materials shall conform the relevant accessibility provisions in 1194 Subparts B and C. NOTE: See the disucssion on alternate format which must be resolved before this can be approved. Also noted from March 29, 2007 meeting wording changes will be made to this to incorportate the phrase "including install, config, activation and use" into describing the types of documents.

(b) Federal agencies shall provide end-users access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request.

(c) Support services for products shall accommodate the communication needs of end-users with disabilities

Best Practice : If the documentation supporting the product, reports or other documentation are to be provided via a contract, then the contract must include this requirement.

If the descriptions for the end-users regarding the accessibility and compatibility features of products in alternate formats are to be provided via a contract, then the contract must include this requirement.

Prior Drafts

Feedback from Barbara Lybarger on February 1, 2007 was to simplify to:

1. All deliverables, including but not limited to reporta, system documentation and end user training or technical support materials, shall be provided in electronic format and shall conform to all relevant sections of this part.

2. All system documentation and end user training or technical support materials shall include both mouse and keyboard command instructions throughout.

3. Alternative formats, as defined in 1194.(?) shall be provided for all deliverables under subsections 1 and 2, above.

4. Technical support shall be delivered in a manner that is functional for requesters with disabilities, such as:

a. appropriate telecommuniation media, including but not limited to TTY, relay service, and video conference, and

b. instructions utilizing command structures appropriate to the disability of the requestor, including but not limited to keyboard equivalents required under S1194.21(?) and S22(?).

c. Memorialization of these and all relevant requirements contained in this part shall be specifically included in all contract documents.

The clarifying language for 1194.41 being proposed by Terry Weaver is based on language that has we have been including in our solicitations for some time now. Our approach (which is also built into the Buy Accessible Wizard) is to require all electronically transmitted deliverables to be in a format that conforms minimally to the web provisions so that we do not have to remediate those deliverables at a later date in order to post them on our intranet or internet sites. Here is a sample:

Deliverables

3.1 All products of this contract must be accessible to people with disabilities. Therefore, all reports and deliverables provided in electronic media, including web-based intranet and internet format, shall conform to the relevant accessibility standards 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. At a minimum, these provisions include:

1194.22 Web-based Intranet and Internet Information and Applications

1194.31 Functional Performance Criteria

1194.41 Information, Documentation, and Support

The FAQs that we have posted on www.section508.gov also address this issue. I am pasting the citation from C.3 Vendor Responsibilities 11 immediately below this paragraph. It clarifies that it is the agencies' responsibility, not the vendor, to comply with 1194.41. It only becomes the vendor's requirement when it is included in a contract.

ii. Do vendors have to provide product documentation in alternate formats?

Yes, if it is a deliverable under a contract. Section 1194.41 of the Access Board's standards provides that product support documentation that is provided to end-users must be made available in alternate format upon request. However, it is the agency's responsibility, not the vendor's, to comply with this provision. Typically, agencies will require such documentation from the vendor to be in an alternate format as part of the deliverables required under the contract. The format of the documentation requested from the vendor may vary. For example, an agency may request the documentation in an electronic format that will allow the agency to reprint information in Braille or alternate formats. Other agencies may request the information to be provided by the vendor in Braille, large print, audio cassette or other format as part of the procurement.

So, to make it more clear in the Access Board's Standards, the initial suggestion follows.:

Subpart D -- Information, Documentation, and Support

§ 1194.41 Information, documentation, and support.

(a) To enable Federal agencies to provide product support documentation to end-users in an accessible format, Federal agencies need to require that all electronically transmitted deliverables, reports or documentation shall conform the relevant accessibility provisions in 1194 Subparts B and C.

(b) If the deliverables, reports or documentation are to be provided via a contract, then the contract must include this requirement.

(c) Federal agencies need to provide end-users access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request.

(d) If the descriptions for the end-users regarding the accessibility and compatibility features of products in alternate formats are to be provided via a contract, then the contract must include this requirement.

(e) Support services for products shall accommodate the communication needs of end-users with disabilities