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Re: It's Official - New Sec. 508 is out

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From: Thomas McKeithan II
Date: Feb 20, 2015 12:15PM

I'd recommend a triannual assessment of regulations in this area.

Respectfully,
Thomas Lee McKeithan II
QSSI
http://www.qssinc.com
508 SME, SSQA Solutions Center
10480 Little Patuxent Pkwy , Suite 350
Columbia , MD 21044
(301 )977-7884 x1058 (Work)
(202) 276-6437 (Cell)
 

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-----Original Message-----
From: <EMAIL REMOVED> [mailto: <EMAIL REMOVED> ] On Behalf Of Chagnon | PubCom
Sent: Friday, February 20, 2015 2:08 PM
To: 'WebAIM Discussion List'
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

Hi Katie,
Do you know if the Access Board's policies on this are public? I didn't find
anything on their website.

I'm curious how "regular basis" is defined. Since WCAG 2.0 was released in
December of 2008, it'll be 6.5 years later when Sec. 508 will formally adopt
it. Is this what the community wants in the future when WCAG 3.0 is
released?

It might require that the Access Board look at and revise its policies and
operating procedures. It's definitely not keeping up with the changes in
technology. I don't say this to criticize the Board, but whatever they're
doing now isn't working well enough for the people that are affected. 6.5
years is too long.

The technologies for ICT are evolving a lot quicker than the technologies
for architectural buildings.

Maybe they're following policies that were set 20-30 years ago, when they
dealt only with architectural barriers.
Maybe they need more full-time staff dedicated to ICT.
Maybe they need their budget increased by Congress.
Maybe they need to change from meeting every two months to every month.

There are many more suggestions how they can improve the review and
acceptance of changing standards, but they should come from the Access Board
itself.

All we, the accessibility community, can do is let the Access Board know
we're not happy with the 6.5 year wait, and that we want them to improve the
delivery of their services to the US community.

--Bevi Chagnon

-----Original Message-----
From: <EMAIL REMOVED>
[mailto: <EMAIL REMOVED> ] On Behalf Of Katie
Haritos-Shea GMAIL
Sent: Friday, February 20, 2015 1:38 PM
To: 'WebAIM Discussion List'
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

The US Access Board already has the responsibility to update and refresh all
of its standards and guidelines on a regular basis.

* katie *
 
Katie Haritos-Shea
Senior Accessibility SME (WCAG/Section 508/ADA/AODA)
 
Cell: 703-371-5545 | <EMAIL REMOVED> | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: <EMAIL REMOVED>
[mailto: <EMAIL REMOVED> ] On Behalf Of Chagnon | PubCom
Sent: Friday, February 20, 2015 1:33 PM
To: 'WebAIM Discussion List'
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

Jon wrote: " Another recommendation that I was considering would be to alter
the nomencalture to allow for advances in technology. For example, they
specifically call out WCAG 2.0 or PDF/UA-1 rather than use a generic
identifier such as, "the current Recommendation" or "the latest version."
By the time this law gets written into the FAR, we might actually have an
update to the current PDF 1.7 specification which could change the needs and
capabilities of ISO 14289."

I'm concerned about that, too. I don't want to wait another 15 years for
WCAG 3.0 to be adopted!

I don't know of any other Federal regulations that automatically incorporate
new versions of "outside" standards (WCAG is not controlled by the US
Federal government, so it is outside our control). I think it's tough to
write language into Sec. 508 itself that would automatically adopt new WCAG
and PDF/UA standards because standards have to have their public comment and
review period.

An alternative might be to have the Access Board's policies state that their
agency has X months to review new versions of WCAG & PDF/UA, go through the
comment and review process, and incorporate them into Sec. 508 standards.

I think we all want Sec. 508 updated as quickly as possible in the future,
especially since we can assume more technologies will be developed faster
and faster each year. Yes, the language of Sec. 508 is fairly
technology-neutral, but we really can't foresee what devices or software
we'll be using 5 years from now.

Regarding abbreviations and unusual words, I think this standard is best
handled by WCAG and WC3's HTML standards. It's not for our specific
government to regulate, but rather an international standard that affects
all technologies. I remember some movement on the abbreviation tags a couple
of years ago. Hopefully someone on this list knows more and will contribute.

--Bevi Chagnon

-----Original Message-----
From: <EMAIL REMOVED>
[mailto: <EMAIL REMOVED> ] On Behalf Of Jon Metz
Sent: Friday, February 20, 2015 1:04 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

Now that we've had a chance to look at the proposed rules, what sort of
things do people believe are should be addressed? Wayne Dick has discussed
the importance of Word Wrapping (1.4.8) in his blog and this is one
requirement that would be beneficial for people with Cognitive and Learning
Impairments.

An area that I would like to see addressed would be the inclusion of 3.1.3
(Unusual Words) and 3.1.4 (Abbreviations) which are recommendations that
would greatly benefit users with Cognitive or Learning Impairments. Since
this law specifically addresses content from the Federal Government, it
behooves them to address the needs of the widest possible audience. Given
their constant overuse of acronyms and occasionally made up words, this
makes perfect sense to include this as a requirement.

Another recommendation that I was considering would be to alter the
nomencalture to allow for advances in technology. For example, they
specifically call out WCAG 2.0 or PDF/UA-1 rather than use a generic
identifier such as, "the current Recommendation" or "the latest version."
By the time this law gets written into the FAR, we might actually have an
update to the current PDF 1.7 specification which could change the needs and
capabilities of ISO 14289.

One of the many complaints about Section 508 has been how it's so outdated.
This would at least help it to avoid the same mistake.

What are other thoughts on this? Is my idea a bad one? What other things are
there?

Thanks!
Jon Metz

On Fri, Feb 20, 2015 at 12:42 PM, Jon Metz < <EMAIL REMOVED> > wrote:

> Dona,
>
> Currently Section 508 does not have separate rules for one Electronic
> and Information Technology (EIT) over another. Everything is wrapped
> within the coziness of the same rules. The conversation of whether or
> not PDF files are included in the guidelines should probably best be
considered opinions.
> Technically it has been up to whether the Section 508 Coordinator
> Offices considered PDFs are considered EIT or not.
>
> This seems to be fortifying the opinion that PDFs are relatively
> important now. In my opinion, the inclusion of PDF/UA is good news in
> my opinion, because so many agencies use PDFs when delivering content.
> Perhaps given the level of effort required to make things PDF/UA will
> help dictate what becomes a PDF in the first place.
>
> Jon
>
>
>
> On Fri, Feb 20, 2015 at 12:20 PM, Dona Patrick < <EMAIL REMOVED> > wrote:
>
>> There were discussions earlier in the month about Section 508 not
>> including PDF files in the guidelines -- that there were techniques
>> but no guidelines in WCAG 2.0.
>>
>> I have been reading through the proposed rule and see that PDF/UA is
>> mentioned a few times. This is good news (right?). I've tried to
>> propose to my company that we use PDF/UA as a standard and this would
>> force us to.
>>
>> Or am I reading it wrong?
>>
>> Dona
>>
>> On Wed, Feb 18, 2015 at 3:28 PM, Chagnon | PubCom
>> < <EMAIL REMOVED> >
>> wrote:
>>
>> > OK, not fully out just yet, but the proposed rule to update the
>> standards
>> > was announced just an hour ago.
>> >
>> > To view the details online, visit
>> >
>> >
>> http://www.access-board.gov/guidelines-and-standards/communications-a
>> nd-it/a
>> > bout-the-ict-refresh/overview-of-the-proposed-rule
>> >
>> > Here's what the US Access Board sent out today.
>> > --Bevi Chagnon
>> >
>> > Begin Quote:
>> >
>> > U.S. Access Board Proposes Updated ICT Accessibility Requirements
>> > The U.S. Access Board has released for public comment a proposed
>> > rule updating accessibility requirements for information and
>> > communication technology (ICT) in the federal sector covered by
>> > Section 508 of the Rehabilitation Act. The rule also would jointly
>> > update guidelines for telecommunications equipment subject to
>> > Section 255 of the
>> Communications
>> > Act.
>> > "The Board's proposal is responsive to widespread changes and
>> innovations
>> > in
>> > the IT and communication industries," states Sachin Dev Pavithran,
>> > Vice Chair of the Access Board. "It is important that the 508
>> > Standards and
>> 255
>> > Guidelines stay abreast of the ever-evolving technologies they
>> > cover so that accessibility for people with disabilities is
>> > properly addressed."
>> > The proposed rule updates various requirements to address
>> > fundamental shifts and trends in the market, such as the
>> > convergence of technologies and
>> the
>> > increasingly multi-functional capabilities of products like smart
>> phones.
>> > Another key goal of this update is to promote consistency with
>> > other requirements in the U.S. and abroad in order to improve
>> > accessibility
>> and
>> > to
>> > facilitate compliance. A leading reference, the Web Content
>> Accessibility
>> > Guidelines (WCAG), is incorporated into the rule and applied to
>> web-based
>> > content as well as to offline documents and software. The Board is
>> > proposing other revisions that will harmonize the rule with
>> > voluntary consensus standards, including those issued by other
>> > countries and international bodies such as the European Commission
>> > due to the global nature of the
>> ICT
>> > market.
>> > The proposed rule specifies the technologies covered and contains
>> > performance-based criteria as well as technical requirements for
>> hardware,
>> > software, and support documentation and services. Access is
>> > addressed
>> for
>> > all types of disabilities, including those pertaining to vision,
>> hearing,
>> > color perception, speech, manual dexterity, reach, and strength.
>> > The proposed rule is based on recommendations from the Board's
>> > Telecommunications and Electronic and Information Technology
>> > Advisory Committee (TEITAC) which comprised a broad cross-section
>> > of stakeholders representing industry, disability groups,
>> > government agencies, and other countries. It also incorporates
>> > public feedback the Board received
>> through
>> > the release of two advance drafts of the rule.
>> > "The significant input the Board has received from stakeholders and
>> > interested parties throughout this process is reflected in the
>> > proposed rule," notes Pavithran. "Such collective feedback is
>> > critical to getting things right in the final rule, and it is no
>> > different with the current proposal, which includes a host of
>> > questions the Board is posing to the public to gather additional
information on various topics."
>> > Public comments on the rule, as well as on a preliminary assessment
>> > of
>> its
>> > estimated costs and benefits, are due in 90 days. The Board also
>> > will
>> hold
>> > public hearings on the rule in San Diego on March 5 and in
>> > Washington,
>> DC
>> > on
>> > March 11. In addition, the Board will conduct a public webinar to
>> > review the proposal on March 31.
>> > Further information on this rulemaking, including a summary of the
>> rule, is
>> > available on the Board's website or by contacting Timothy Creagan
>> > at
>> (202)
>> > 272-0016 (v), (202) 272-0074 (TTY), or <EMAIL REMOVED> .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to <EMAIL REMOVED>
>> >
>> >> >> list messages to <EMAIL REMOVED>
>>
>
>
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