Note

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May Report to TEITAC

Contents

WORKING DRAFT of GENERAL Results

this is the working draft page for our committee


I.  Material which can be described as “Changes to Existing Provisions”

  1. Modification – Material which modifies existing provisions.
  2. Rationale – Why is this change suggested?


Current provision Keep current language Change Group? Modification Rationale:  Why is this change suggested? Cost Impact
  1194.26 (c) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.   Yes   Came here from Hardware   No   No impact.
  {508} S 1194.31 (a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.

{255}S 1193.41 (*)(a) Operable without vision. Provide at least one mode that does not require user vision.

 No  No   At least one mode shall be provided that allows full use of product without using vision, directly or with users' AT.   Fixes 3 problems. 1- full use required for direct or AT, 2 - functions might be mixed (direct & AT) 3 - in order to be accessible via AT it must be AT users' have. (We have not specified which users). No impact. Text clarified which would cause minor decrease in implementation costs.
  {508} S 1194.31 (b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired shall be provided.


{255}S 1193.41 (*)(b) Operable with low vision and limited or no hearing. Provide at least one mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio output.

 No  No  At least one mode shall be provided that allows full use of product without requiring visual acuity greater than 20/70, and that allows audio and enlarged text output to work together or independently, directly or with users' AT.   Fixes same 3 problems No impact. Text clarified which would cause minor decrease in implementation costs.
  {508}S 1194.31 (c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for assistive technology used by people who are deaf or hard of hearing shall be provided.

{255} S 1193.41 (*)(d) Operable without hearing. Provide at least one mode that does not require user auditory perception.

 No  No   At least one mode shall be provided that allows full use of product without using hearing, directly or with users' AT.   Fixes same 3 problems No impact. Text clarified which would cause minor decrease in implementation costs.
  {508} S 1194.31 (d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.


{255}S 1193.41 (*)(b) Operable with low vision and limited or no hearing. Provide at least one mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio output.

 No  No  Where audio information is important for the use of a product,At least one mode shall be provided that allows full use of product with enhanced audio, directly or with users' AT.   Fixes same 3 problems No impact. Text clarified which would cause minor decrease in implementation costs.
  {508} S 1194.31 (e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for assistive technology used by people with disabilities shall be provided.


{255}S 1193.41 (*)(h) Operable without speech. Provide at least one mode that does not require user speech.

 No  No  At least one mode shall be provided that allows full use of product without using speech, directly or with users' AT.   Fixes same 3 problems No impact. Text clarified which would cause minor decrease in implementation costs.
  {508} S(1194.31 (f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.


{255}S 1193.31 (*)(e) Operable with limited manual dexterity. Provide at least one mode that does not require user fine motor control or simultaneous actions. S 1193.41 (*)(f) Operable with limited reach and strength. Provide at least one mode that is operable with user limited reach and strength.

 No  No  At least one mode shall be provided that allows full use of product with limited reach and strength and without simultaneous actions, directly or with users' AT.   Fixes same 3 problems PLUS adds AT in a way that works (since good for some parts but not for others) Adds AT option. Should potentially reduce cost to companies by giving additional options - and increase productivity and employment by people with disabilities. So this would decrease costs and increase benefits.
  {508} NONE
{255}S 1193.41 (*)(i) Operable with limited cognitive skills. Provide at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user.
 No  No  At least one mode shall be provided that accommodates cognitive, language or learning impairments, directly or with users' AT.   To cover cognitive, language and learning aspects. This is one of the largest or the largest group of people with disabilities in the government. The cost in increased productivity can be great. Even simplification act has talked about using plain language. And GSA reports that there is some guidance there to use plain language. The cost to learn to write plainly though is not known or other aspects of this. The benefits are believed to outweigh costs in the end however so a net decrease in cost is believed.
  {508}"S 1194.21 (k) Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.


S 1194.22 (j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
S 1194.25 (i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz."
{255}S 1193.43 (*)(f) Prevention of visually-induced seizures. Visual displays and indicators shall minimize visual flicker that might induce seizures in people with photosensitive epilepsy.

 No     At LEAST needs to be 50 HZ

should be changed to limit to flashing no more than 3 per 1 second period that are larger that is greater 25% of the central 10 degrees of vision. (that can be made simpler by assuming viewing distance) That will eliminate worrying about small indicators or areas of the screen. Haven't worked on this yet. NOTE: Keeping flashing to less than 3 per 1 second period would meet the above spec.

  General since it can be hardware, software, Media, Content. @@ should add text to indicate that is is to avoid seizures not distraction. Should lower costs by allowing removing Flash restrictions from things that are not problems.


II.  Entirely New Provisions

New provision Rationale:  What issue does this provision address?
   
   

III.  Other Material

A.  Recommendations on organization of the provisions

Committee Conclusions on Format

  1. Can't use 508 organization - that is mixed product domains, characteristics and applications.
  2. Can't use committee structure directly because some committees are product function (telecom) while some are characteristics (closed, involve hardware) and some are mixed (have software with an OS + content).
  3. Recommend a linear sortable presentation of the provisions that does not try to organize them by technology or disability.
    • This listing can then be sorted or filtered to show which would apply to different domains, product types, applications or disabilities.
    • This would also facilitate incorporation into an updated "buy accessible" tool.

3 Formats

The General Group has Three proposals for Re-Organization

  • FORMAT 2 evolved from #1 and a request to align the categories with the working groups.
    • It is same as previous #2 except that CONTENT section was moved down so that all device provisions are together.
  • FORMAT 3 is same as #2 with the following changes
    • AudioVideo was divided into AudioVideo Content the went to Content' and AudioVideo Players that went to Software-General {from a comment form AV co-chair - just to explore topic}
    • A category was added under Content for non-Web Content {per note to list by Terry Weaver}

B1.  Issues this subcommittee has not yet addressed, but which should be addressed.

  • how to incorporate 'sufficient techniques' idea
  • bios questions
  • issues for cognitive language and learning
  • whether there is something to be done in allergy area
  • A method shall be provided to stop any blinking or movement that lasts more than 3 seconds. This is a first pass and needs work. Also check to be sure it isnt too broad. 1194.21(h) covers this for animation in software. Is this the only technology (thus should this go to software/web??)
  • Relationship of functional performance to closed?


B2.  Issues this subcommittee is not addressing, but which should be addressed.

  • review of other standards to determine provisions that need to be added
    • to make up for gaps in this standard
    • to cover new aspects not there or clear last time around
    • to increase quality of the standard
  • Cooperation between AT. (Should we even be talking about what AT should do? It is an adaptation to E&IT not an E&IT)

(some of this is being done in some other groups )


C.   Recommendations relating to Themes or other content.

D.   Recommendations regarding process: the work of the subcommittees, the whole Committee, liaison with the Access Board, etc.

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