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RE: VPAT E-learning

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From: Jim Thatcher
Date: Feb 22, 2006 7:00AM


Hi Norman,

You mentioned:
> Conceptually 1194.22 (web-based intranet and internet) standards
> are a subset of 1194.21 (software and operating systems).

I don't agree with that at all. As you mention, the web standards call on
the software standards for applets and plug-ins, and though rarely mentioned
a browser itself must pass the software provisions - but that's it; 1194.22
is not conceptually a subset of 1194.21. In particular you suggested

> Legally, I think if you can prove you meet the 1194.22 for web
> content then you've met the more specific standards.

I wish it were so. A frightening example today is AJAX. You can have content
that looks like a software dialog box, passes 1194.22 and totally fails key
provisions in 1194.21.

Jim

Accessibility Consulting: http://jimthatcher.com/
512-306-0931

-----Original Message-----
From: <EMAIL REMOVED>
[mailto: <EMAIL REMOVED> ] On Behalf Of Robinson, Norman
B - Washington, DC
Sent: Wednesday, February 22, 2006 7:23 AM
To: WebAIM Discussion List
Subject: RE: [WebAIM] VPAT E-learning

Andrew,

Conceptually 1194.22 (web-based intranet and internet) standards
are a subset of 1194.21 (software and operating systems). The specific
web standards were an attempt to be more specific in what technical
standards were required to provide access. Note that for some content
(plugins) the web content references back to the more 'generic' software
standards
(http://www.usps.com/cpim/ftp/hand/as508a/508a_c6.html#508hdr69).
Legally, I think if you can prove you meet the 1194.22 for web content
then you've met the more specific standards. There is discussion in the
Section 508 preamble that goes into the rationale if anyone is
interested: http://www.access-board.gov/sec508/preamble.htm.

Regards,


Norman B. Robinson

-----Original Message-----
From: <EMAIL REMOVED>
[mailto: <EMAIL REMOVED> ] On Behalf Of Andrew
Kirkpatrick
Sent: Tuesday, February 21, 2006 3:20 PM
To: WebAIM Discussion List
Subject: RE: [WebAIM] VPAT E-learning


> You would include provisions from 1194.21(a-l) only for
> "software" that might include Java. Interactive elements
> would not require 1194.21 provisions as these are addressed
> by provisions from 1194.22. you also probably would not need
> 1194.24 provisions as 1194.22(b) generally addresses
> multimedia content.

22a and 22b together do address the need for captions, but audio
descriptions are not required unless .24 standards are addressed.

What is not clear is whether it is being argued that 1194.21 applies to
websites with interactivity because the 11194.22 standards are
insufficient to address all of the issues that these types of site have
and that should be dealt with, or if that is what the standards indicate
should be done.

The .22 standards are titled "Web-based Intranet and Internet
Information and Applications" which would seem to include interactive
web sites, including those using javascript to create this
interactivity. 1194.22(l) addresses this point in its reference to
scripting.

I'm not saying that meeting the requirements of 1194.22 fully addresses
the needs of all users, but that isn't the point here. Since we are
dealing with a law, we need to be clear on what the law actually says
instead of what we think it should say.

AWK