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Thread: VPAT E-learning
Number of posts in this thread: 14 (In chronological order)
From: priti
Date: Tue, Feb 21 2006 6:20AM
Subject: VPAT E-learning
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Hi All,
Voluntary Product Accessibility Template (VPAT) is posted to state the company's stand on accessibility for different products and services. I have a query relating to the same. If a vendor wants to post the VPAT for an e-learning course, which section 508 guidelines are applicable for e-learning course?
Which of the section 508 standards will the VPAT of an e-learning course include? I would be also interested to view an on-line example of such a VPAT. Links for such examples would be of great help...
Regards,
Priti Rohra
Accessibility Tester
Net Systems Informatics (I) Pvt. Ltd.
India
Tel: 91-22-26860485/6 extn: 28
E-mail: = EMAIL ADDRESS REMOVED =
Url: www.n-syst.com
From: Jon Gunderson
Date: Tue, Feb 21 2006 7:40AM
Subject: Re: VPAT E-learning
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Here is an example VPAT:
http://www.accessiblewizards.uiuc.edu/vindex.php
What VPAT you develop for a course would depend on the
technologies.
If is just static HTML:
1194.22 Web-based intranet and internet information and
applications. 16 rules.
If there are interactive components or other software:
1194.21 Software applications and operating systems.
If there is multi-media, some of these may apply:
1194.24 Video and multimedia products.
In any case you would probably want to state which
requirements you course needs to comply with and which they do
not.
Jon
---- Original message ----
>Date: Tue, 21 Feb 2006 18:41:46 +0530
>From: "priti" < = EMAIL ADDRESS REMOVED = >
>Subject: [WebAIM] VPAT E-learning
>To: "WebAIM Discussion List" < = EMAIL ADDRESS REMOVED = >
>
> Hi All,
> Voluntary Product Accessibility Template (VPAT) is
> posted to state the company's stand on accessibility
> for different products and services. I have a query
> relating to the same. If a vendor wants to post the
> VPAT for an e-learning course, which section 508
> guidelines are applicable for e-learning course?
> Which of the section 508 standards will the VPAT of
> an e-learning course include? I would be also
> interested to view an on-line example of such a
> VPAT. Links for such examples would be of great
> help...
>
> Regards,
> Priti Rohra
> Accessibility Tester
> Net Systems Informatics (I) Pvt. Ltd.
> India
> Tel: 91-22-26860485/6 extn: 28
> E-mail: = EMAIL ADDRESS REMOVED =
> Url: www.n-syst.com
>________________
>
>
>
Jon Gunderson, Ph.D.
Director of IT Accessibility Services
Campus Information Technologies and Educational Services (CITES)
and
Coordinator of Assistive Communication and Information Technology
Disability Resources and Education Services (DRES)
Voice: (217) 244-5870
Fax: (217) 333-0248
Cell: (217) 714-6313
E-mail: = EMAIL ADDRESS REMOVED =
WWW: http://cita.rehab.uiuc.edu/
WWW: https://netfiles.uiuc.edu/jongund/www/
From: Andrew Kirkpatrick
Date: Tue, Feb 21 2006 8:00AM
Subject: RE: VPAT E-learning
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> If is just static HTML:
> 1194.22 Web-based intranet and internet information and
> applications. 16 rules.
>
> If there are interactive components or other software:
> 1194.21 Software applications and operating systems.
Jon,
This is a pretty slippery slope you've just described. Can you clarify
what you would classify as "interactive components"?
Thanks,
AWK
From: Karl Groves
Date: Tue, Feb 21 2006 10:20AM
Subject: RE: VPAT E-learning
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Jon -
Can you describe exactly what "DHTML" techniques which would not fit into
1194.22?
Karl L. Groves
>
From: Jon Gunderson
Date: Tue, Feb 21 2006 10:30AM
Subject: RE: VPAT E-learning
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Andrew,
1. The line is blurring between the Web requirements and the
Software requirements of Section 508 as DHTML techniques
continue to be used to create a new generation of Web
Applications.
2. If on-line learning technologies are also part of your
course, the accessibility of those technologies should also
be a consideration. This may trigger the requirements of
both Software and Multi-media Section 508 requirements.
3. What technologies are being used to create and deliver
course materials?
Jon
---- Original message ----
>Date: Tue, 21 Feb 2006 06:54:04 -0800
>From: "Andrew Kirkpatrick" < = EMAIL ADDRESS REMOVED = >
>Subject: RE: [WebAIM] VPAT E-learning
>To: "WebAIM Discussion List" < = EMAIL ADDRESS REMOVED = >
>
>> If is just static HTML:
>> 1194.22 Web-based intranet and internet information and
>> applications. 16 rules.
>>
>> If there are interactive components or other software:
>> 1194.21 Software applications and operating systems.
>
>Jon,
>This is a pretty slippery slope you've just described. Can
you clarify
>what you would classify as "interactive components"?
>Thanks,
>AWK
>
>
>
Jon Gunderson, Ph.D.
Director of IT Accessibility Services
Campus Information Technologies and Educational Services (CITES)
and
Coordinator of Assistive Communication and Information Technology
Disability Resources and Education Services (DRES)
Voice: (217) 244-5870
Fax: (217) 333-0248
Cell: (217) 714-6313
E-mail: = EMAIL ADDRESS REMOVED =
WWW: http://cita.rehab.uiuc.edu/
WWW: https://netfiles.uiuc.edu/jongund/www/
From: Jon Gunderson
Date: Tue, Feb 21 2006 11:00AM
Subject: RE: VPAT E-learning
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Some examples:
From: Hoffman, Allen
Date: Tue, Feb 21 2006 12:50PM
Subject: RE: VPAT E-learning
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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.
The important aspect to completing VPAT(s) is to be clear, "yes", "no"
and if "yes", but these exceptions, be clear about where they occur, and
their impact.
You should consider completeing the 1194.31 functional performance
criteria as well as these are always applicable. Including answers to
applicable provisions from 1194.41 is helpful as well.
Allen Hoffman
DHS : OCIO; Section 508 PMO
v: 202-692-4386; c: 202-213-1835; tty: 202-401-0725
email: = EMAIL ADDRESS REMOVED = or = EMAIL ADDRESS REMOVED =
This communication, along with any attachments, is covered by federal
and state law governing electronic communications and may contain
sensitive and legally privileged information. If the reader of this
message is not the intended recipient, you are hereby notified that any
dissemination, distribution, use or copying of this message is strictly
prohibited. If you have received this in error, please reply
immediately to the sender and delete this message.
Thank you.
From: Andrew Kirkpatrick
Date: Tue, Feb 21 2006 1:30PM
Subject: RE: VPAT E-learning
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> 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
From: priti
Date: Tue, Feb 21 2006 10:40PM
Subject: Re: VPAT E-learning
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Hi John,
In my opinion, Section 1194.31 & 1194.41 will also be applicable.
Section 1194.31 Functional performance criteria standards should also be
covered as they need to be complied with, for an accessible e-learning
application.
Section 1194.41 Information, documentation and support should also be
covered in the case of an e-learning application help for the same should be
provided to the users in alternate format upon request.
Regards,
Priti Rohra
Accessibility Tester
Net Systems Informatics (I) Pvt. Ltd.
India
Tel: 91-22-26860485/6 extn: 28
E-mail: = EMAIL ADDRESS REMOVED =
Url: www.n-syst.com
----- Original Message -----
From: "Jon Gunderson" < = EMAIL ADDRESS REMOVED = >
To: "WebAIM Discussion List" < = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, February 21, 2006 8:07 PM
Subject: Re: [WebAIM] VPAT E-learning
> Here is an example VPAT:
> http://www.accessiblewizards.uiuc.edu/vindex.php
>
> What VPAT you develop for a course would depend on the
> technologies.
>
> If is just static HTML:
> 1194.22 Web-based intranet and internet information and
> applications. 16 rules.
>
> If there are interactive components or other software:
> 1194.21 Software applications and operating systems.
>
> If there is multi-media, some of these may apply:
> 1194.24 Video and multimedia products.
>
> In any case you would probably want to state which
> requirements you course needs to comply with and which they do
> not.
>
> Jon
>
> ---- Original message ----
> >Date: Tue, 21 Feb 2006 18:41:46 +0530
> >From: "priti" < = EMAIL ADDRESS REMOVED = >
> >Subject: [WebAIM] VPAT E-learning
> >To: "WebAIM Discussion List" < = EMAIL ADDRESS REMOVED = >
> >
> > Hi All,
> > Voluntary Product Accessibility Template (VPAT) is
> > posted to state the company's stand on accessibility
> > for different products and services. I have a query
> > relating to the same. If a vendor wants to post the
> > VPAT for an e-learning course, which section 508
> > guidelines are applicable for e-learning course?
> > Which of the section 508 standards will the VPAT of
> > an e-learning course include? I would be also
> > interested to view an on-line example of such a
> > VPAT. Links for such examples would be of great
> > help...
> >
> > Regards,
> > Priti Rohra
> > Accessibility Tester
> > Net Systems Informatics (I) Pvt. Ltd.
> > India
> > Tel: 91-22-26860485/6 extn: 28
> > E-mail: = EMAIL ADDRESS REMOVED =
> > Url: www.n-syst.com
> >________________
> >
> >
> >
>
>
> Jon Gunderson, Ph.D.
> Director of IT Accessibility Services
> Campus Information Technologies and Educational Services (CITES)
> and
> Coordinator of Assistive Communication and Information Technology
> Disability Resources and Education Services (DRES)
>
> Voice: (217) 244-5870
> Fax: (217) 333-0248
> Cell: (217) 714-6313
>
> E-mail: = EMAIL ADDRESS REMOVED =
>
> WWW: http://cita.rehab.uiuc.edu/
> WWW: https://netfiles.uiuc.edu/jongund/www/
>
>
>
>
>
>
>
>
From: Robinson, Norman B - Washington, DC
Date: Wed, Feb 22 2006 6:20AM
Subject: RE: VPAT E-learning
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Priti,
I'd actually like to draw your attention to something that should
_NOT_ be in a VPAT - "stating the company's stand on accessibility".
I can't tell you how many VPAT's I've reviewed where companies have
done just that, wasting their and my time on nonsense. The VPAT is only
a very basic tool to outline what Section 508 technical standards apply
to a specific implementation (e.g., a new version might need a new VPAT,
a version on OS X or Linux would require their own VPAT separate from
Windows).
To answer your question, it depends. Most web content is covered
under the technical provisions for web content. However proprietary Java
players or courseware could have the technical provisions for software
and operating systems apply. If the course relies on plug-ins, the that
is covered by the web provisions, with references to specific software
provisions. If there is multimedia, those provisions apply as well.
Microsoft has done a good job of providing VPATs for most of their
products:
http://www.microsoft.com/Industry/government/section508.mspx#ECAA
<http://www.microsoft.com/Industry/government/section508.mspx#ECAA>; .
The ITIC came up with the VPAT concept. You might wish to view their
template:
http://www.itic.org/archives/articles/20040506/voluntary_product_accessi
bility_template.php
<http://www.itic.org/archives/articles/20040506/voluntary_product_access
ibility_template.php> .
Finally, please note that the VPAT is what government procurement is
trained to ask for and thus it is wise to have one for a product. There
should be additional information for the technical team to evaluate that
the VPAT doesn't address, such as how you tested (with what assistive
technology if any), what version was tested (some VPATs are generic and
_dated_), who tested (vendor or 3rd party expert), and other details
such as if not in compliance, known work arounds to provide
accessibility (e.g., there may not be alt text as required by law but
the application could be self-voicing and thus meet the functional
requirements).
Hope that helps,
Norman B. Robinson
From: Robinson, Norman B - Washington, DC
Date: Wed, Feb 22 2006 6:30AM
Subject: RE: VPAT E-learning
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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
From: Andrew Kirkpatrick
Date: Wed, Feb 22 2006 6:50AM
Subject: RE: VPAT E-learning
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Norman,
I'll agree that there is a high degree of overlap between 22 and 21, but
not that 22 is a subset, since there are things in 22 that are not in 21
(e.g. 22o [skip repetitive links] and 22b [synch multimedia
equivalents]).
What I'm concerned about is the desire to view interactive web
applications as needing to adhere to the 21 standards because there are
shortcomings in the 22 standards for these types of apps. I absolutely
agree that the sentiment is correct in that a complex web application
should be accessible beyond what is directly mandated in subpart 22, but
when considering 508 compliance it is important to adhere to the
categories that are provided for in the law even if you consider them
inadequate.
AWK
>
From: Jim Thatcher
Date: Wed, Feb 22 2006 7:00AM
Subject: RE: VPAT E-learning
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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
From: Robinson, Norman B - Washington, DC
Date: Thu, Feb 23 2006 6:00AM
Subject: RE: VPAT E-learning
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Andrew,
My perspective is that if someone began describing software on
the computer and attributes and user interaction, I would begin by
asking if this falls under .21 (Software). If it then was revealed it is
web content, then the specifics of .22 (web) apply and because they are
more specific they are the technical requirements for that content type,
and legally if you meet those requirements you are in compliance.
Certainly, I am advocating a stronger tie between software and
web standards if the Access Board ever revises the standards. I think
the web was so new their wasn't enough experience to provide a better
perspective and see that web content is no different from C++ content or
Java content or VisualBasic content or XML content; that is a language,
whether interpreted or not that can display or interact.
The reason I bother with explaining this is that the web browser
itself falls under .21 (as software) however the web content doesn't
directly, but with various perceptions and multiple user agents that
aren't web browsers, one could argue the point. And, if you take the
fish out of water it has trouble breathing; asking a vendor what
browser/user-agent was required (reminds me of compatible-AT link in a
VPAT) for their application kind of sets up the conversation for
testing, timeouts, and how Software standards might apply...
But, beyond friendly discussion of the issues, I'd say you are
correct. LEGALLY Section 508 is constrained by how it is written.
Complex web applications fall under .22 (web) and unless they use
plug-ins or some other non-HTML technology (such as Java) then that is
the only standard that you can legally apply.
AJAX is not an exception. It generally falls under web
applications (barring embedded Java, plug-ins, etc.). Viewed as an
application, I could see how it might fail to meet the Section 508
software technical standards. Just as web technologies such as AJAX
change how web content is presented, I think the Section 508 standards
will have to change.
Until then, I can make arguments that existing web content
hasn't been judged strictly enough. Would an AJAX dialog box mocked up
to look like a system dialog box be an "electronic form"? Perhaps. Alt
text for those "system widgets" would be required. More importantly,
vendors should look forward to section (l) (When pages utilize scripting
languages to display content, or to create interface elements, the
information provided by the script shall be identified with functional
text that can be read by assistive technology) being used as a bigger
stick. AJAX relies on scripting to display content. It better be
available. The preamble to 508 mentions "if a web page uses a script to
create a graphic map of menu choices when the user moves the pointer
over an icon, the web site designer may be required to incorporate
"redundant text links" that match the menu choices because functional
text for each menu choice cannot be rendered to the assistive
technology". One could debate over "graphic map" vs. "visual map" but
I'd not hesitate to say they are one in the same in this discussion. I
also expect if I took the hard-line on requiring readability without
style sheets many AJAX applications would have to be modified. Finally,
I expect a passive-aggressive stance on (p; timeouts) would make a legal
requirement for notification of timeouts an issue with some AJAX
applications (e.g., Oh, you want to log out the user? Why? No activity?
They didn't know the page updated? Well you have to notify them first).
The human side of the story is asking a vendor "Do you want to spend
your time explaining why Section 508 doesn't apply or make your
application work for my users so I can buy it?"
The biggest issue is the update of the user display. This is
covered by .21 (Software) section (c; well-defined on-screen indication
of current focus) and (d; info about user interface elements, including
identity, operation, and state). However, The Access Board (responsible
for the technical standards) did not adopt WCAG 1.0 Checkpoint 6.2;
"[e]nsure that equivalents for dynamic content are updated when the
dynamic content changes." I think if they did, AJAX would be covered.
I can tell you that if my agency is building an application, not
taking the user interface update into account isn't acceptable. It won't
pass my review - it is bad coding! I have no problem with stating an
application might be Section 508 compliant if it technically complies. I
also have no problem stating to a Vendor if their solution doesn't take
into account use by assistive technology, isn't accessible because they
didn't test for a that use-case, then it lacks quality and is bad for
our users. Next product please.
Failing that and having business justifications for purchase of
an AJAX type application (not developed but purchased COTS style) then I
guess users can refresh their web browsers and assistive technology to
get access. Is that legal? Probably. Could we do better? Definitely. Do
I expect some smart AJAX programmer can devise a way to refresh the web
browser such that screen readers automatically read because of changes?
Yes. Hope it happens soon so we can set that as a minimum requirement
for AJAX-style technology.
Regards,
Norman B. Robinson