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Re: The ITIC updated VPATs


From: Sailesh Panchang
Date: Dec 20, 2018 2:10PM

Here are my observations and suggestions that I have submitted to ITIC
with the hope they will be considered for 2019 versions. VPAT 2.3
incorporating WCAG 2.1 was released today.

1. VPAT is a registered mark and there are some essentials one is
supposed to adhere to. Yet it permits a lot of flexibility: use single
table or have separate tables for different content types, drop rows
for subsections (in S508) / use HTM or PDF or presumably XLS formats,
break up the report into multiple parts for a complex product and so
And yet it says one should not materially deviate from the format.
This is confusing … with so much scope for deviating!

2. Every cell of the WCAG tables (for the different VPAT types S508 /
WCAG etc). has "labels" for different content types (Web / software /
authoring tools / docs). Visually it may not pose a problem but
screen reader users will have a hard time filling this out or even
reading the content meaningfully.
The alternative presentation that is permitted - using separate tables
for different content types will work for all users and be an easy
read. In fact creating one VPAT for different content types is
problematic because they could be on different platforms and support
and remarks may differ.
I suggest that the instructions should indicate that users should
insert separate tables for the different content types that apply or
create a separate VPAT for each content type. I think ITIC is in a
great position to influence the creation of a separate VPAT for each
content type. These can be separate docs or combined into one
depending on client's needs / usage.

3. In stand alone WCAG2 format too every table cell has labels for the
different content types. WCAG does not define these content types
although one can apply WCAG to them. I was intrigued by this

4. The instructions state that the VPAT maybe used for revised /
corrected or final S08 standards of 2017, and 2018... why not just
say the final S508 one only?

5. As one is permitted to do away with entire sections / tables that
do not apply, it may help to have a single version with the WCAG 2
tables and then define additional sections for S508, EN 301-549. The
instructions for authors may state these sections may be retained
only for reports based on those standards.

6. I also see the instructions for the different VPAT types (S508 /
WCAG / EU / all in one) have very little that is different.
Therefore, if a single VPAT is drawn up as per #5 above, the
instructions should also be organized along those lines: applicable
to WCAG only/ applicable if S508 is used / applicable if EN 301-549 is used.

Thanks and best wishes,

Sailesh Panchang
Principal Accessibility Consultant
Deque Systems Inc
Phone 703-225-0380 ext 105
Mobile: 571-344-1765

On 12/20/18, Jeff Kline via WebAIM-Forum < <EMAIL REMOVED> > wrote:
> Is it just me, or does anyone else think that there are too many, "audience
> specific" versions of the updated VPAT form.
> I am trying to understand why we need separate templates for WCAG, EN, 508,
> and International. I still see many manufacturers (mfrs) struggling with
> just the basics of completing a VPAT 1.0 (Yes....sad but true) so sending
> them out to the ITI VPAT page to choose from multiple versions of the form
> is problematic and will likely introduce additional complexity and
> confusion.
> Also, it seems to me that, many IT mfrs operate internationally and would
> need the EN section completed anyway, so why make it a separate template?
> This potentially forces mfrs to maintain multiple versions of ACRs for a
> single product when one would suffice. (With added pain and cost I might
> add) If I put my mfr business hat back on, I know that as a mfr, I would
> not be very happy about this.
> On the procurement site, there is also the possibility that the procuring
> entity could receive different versions of the form from different mfrs,
> which could make it more difficult to compare the offerings.
> Why there isn't a single version that incorporates the criteria from all of
> the standards now covered. Wait! There is one! It's the International
> Version!!
> For US procurement organizations, public or private, they can point directly
> to the International (full) Version on the ITI website, and specify in the
> solicitation, SOW, etc., which sections of that form are required to be
> completed. For example, Texas would require the WCAG A, AA, and applicable
> sections of 508. (depending on the type of product or service being
> procured) That way, mfrs could use the single version of the form for all
> their business needs including the EN stuff, which we in the US can just
> ignore if its there.
> So, wouldn't it make sense for ITI to publish only the "universal"
> (International) version or am I missing something?
> Jeff Kline
> Program Director
> Statewide EIR Accessibility
> Texas Department of Information Resources
> Phone 512.463.3248
> Mobile 512.426.9779
> > > > >