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Thread: Non-Government Docs and 508

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From: Randy P
Date: Sat, Feb 14 2009 12:00PM
Subject: Non-Government Docs and 508
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Hi,

We are working as contractors for a US federal government agency, and
a question has arisen concerning the posting of non-Government
documents (mostly PDF) on Government websites.

The agency regulates an industry and frequently takes enforcement
actions against companies. The companies respond with letters that are
received by fax or mail, never electronically. In the interest of
Government transparency, they want to scan these company responses and
place the scanned images on a public Government website. The scanned
documents are not accessible and the companies are not required by law
to submit accessible documents. Question: Can the agency place these
documents on their website as is?

Thanks for any input.

From: Chris Hoffman
Date: Sun, Feb 15 2009 12:10PM
Subject: Re: Non-Government Docs and 508
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Hi Randy,

Looking at Section 508 1194.2 (1), "When compliance with the
provisions of this part imposes an undue burden, agencies shall
provide individuals with disabilities with the information and data
involved by an alternative means of access that allows the individual
to use the information and data," and 1194.22 (a), "A text equivalent
for every non-text element shall be provided (e.g., via 'alt',
'longdesc', or in element content)," it seems fairly clear that you
would need to have accessible transcripts of the letters alongside the
originals.

Perhaps you could have a notice to the effect of, "Response letters
from companies available on request," to avoid having to transcribe
them all at once.

Chris

On Sat, Feb 14, 2009 at 1:56 PM, Randy P < = EMAIL ADDRESS REMOVED = > wrote:
> Hi,
>
> We are working as contractors for a US federal government agency, and
> a question has arisen concerning the posting of non-Government
> documents (mostly PDF) on Government websites.
>
> The agency regulates an industry and frequently takes enforcement
> actions against companies. The companies respond with letters that are
> received by fax or mail, never electronically. In the interest of
> Government transparency, they want to scan these company responses and
> place the scanned images on a public Government website. The scanned
> documents are not accessible and the companies are not required by law
> to submit accessible documents. Question: Can the agency place these
> documents on their website as is?
>
> Thanks for any input.
>