EWG:Draft Aug 17: Subpart A Comments
Editorial Working Group > Aug 17 Draft
This page is for discussion and proposed edits of the provisions in this section
Discussion for Section 1194.3 General Exceptions
1194.3 - A - Intelligence Or Security Systems
The proposed addition of "Physical prerequisites for personnel, also known as "fitness for duty", are not valid basis to meet national security or other exceptions in this part." has, at the request of Allen Hoffman, DHS been retracted and replaced with a request for consideration of a new Emergency, Field and First Response Use clause.
1194.3 - NEW - Emergency, Field and First Response Use
This new exception has been added at the request of Allen Hoffman of DHS.
1194.3 - E - Fundamental Alteration
The proposed versions has been reduced to only two.
Version 1 (was called #4 before)
This part shall not be construed to require a fundamental alteration in the nature of the E&IT, or its components, OR THE AGENCIES SPECIFIED PRODUCT REQUIREMENTS OR BUSINESS NEED.
Rationale for Version 1: This incorporates the changes that were in the Aug 17 versions 1-4. It limits the exception to the nature of the E&IT or its components and those requirements “specified by the agency” (assuming they are constructed in accordance with standard procurement procedures). It added the phrase "of the agencies specified prodcut requirements" to not specify that it also applies to components, but may be viewed as more open with regard to allowing the agency to tie the exception to the business need even if the requirements are not specified up front. The authors recommend that the TEITAC adopt this version of the proposed language specifically to remind agencies that their implementation of Section 508 must support both the agency’s mission as well as their responsibilities under Section 508. This version demonstrates how the discussion has evolved to clarify that E&IT (previously referred to as “product”) and components are covered. This version also links the fundamental alteration to the agencies specified requirements- if they are able to specify their requirements – or their business need if they are not able to specify the requirements up front.
Version 2
Retain current provision
Rationale for Version 2 Additional wording intended to clarify that agency’s specified product requirements (assuming they are constructed in accordance with standard procurement procedures) do not need to be altered. Some TEITAC members indicated this additional language is not needed, as it is implicit.
1194.3 - F - Service Areas
The proposed versions has been reduced to only two.
Version 1
Products designed for spaces frequented only by service personnel for maintenance, repair, or occasional monitoring of equipment and whose controls or interfaces can be executed solely from these spaces are not required to comply with this part. This part does apply to E&IT designed for spaces frequented only by service personnel, but whose controls or interfaces can be executed externally or remotely.
Rationale for Version 1 Additional wording attempts to restrict this exception to products that are specifically designed to be located in areas frequented only by service personnel rather than covering all products by virtue of their location. It also makes clear that being able to support the system remotely is acceptable.
- Impact:
- External Reference:
- Testability:
Version 2
Remove the current provision.
Rationale for Version 2 Some TEITAC members and subcommittee members recommend the entire exception should be deleted. This recommendation is based on the preference that all products should conform regardless of location and use.
- Impact:
- External Reference:
- Testability:
1194.3 - G - Narrow, Delineated Use
This is an entirely new section. Version 2 is withdrawn. There are concerns in how the funcitonal performance criteria could impact the item. Since they would apply to closed products, it's not clear on how this would be implemented. There is disparity on how to approach the topic of products with a narrow delineated use.
Comparable Access
This term will not be defined.
General Flash and Red Flash Thresholds
(Flashing frequency corrected from 50 to 55 Hz in bulleted list, update made Aug 28, 2007)
A sequence of flashes or rapidly changing image sequences where all three of the following occur:
- There are more than three flashes within any one-second period; and
- The flashing is below 55 Hz; and
- The combined area of flashes occurring concurrently and contiguously occupies more than a total of .006 steradians (25% of any 10 degree visual field on the screen).
- For the general flash threshold, a flash is defined as a pair of opposing changes in relative luminance of 10% or more and the relative luminance of the darker image is below 0.80. An "opposing change" is an increase followed by a decrease, or a decrease followed by an increase.
- For the red flash threshold, a flash is defined as any transition to or from a saturated red.
- Note 1: Flashing that is less than 3 per second or greater than 50 hz automatically passes(see #1 and #2 above)
- Note 2: For general Web content, using a 341 x 256 pixel rectangle anywhere on the displayed screen area when the content is viewed at 1024 x 768 pixels will provide a good estimate of a 10 degree visual field for standard screen sizes and viewing distances.
