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

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Number of posts in this thread: 23 (In chronological order)

From: Chagnon | PubCom
Date: Wed, Feb 18 2015 1:28PM
Subject: It's Official - New Sec. 508 is out
No previous message | Next message →

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-and-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 ADDRESS REMOVED = .

From: Angela French
Date: Wed, Feb 18 2015 2:40PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

I wonder why they don't put a date on the web page? I wish they would.

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Chagnon | PubCom
Sent: Wednesday, February 18, 2015 12:28 PM
To: WebAIM Discussion List
Subject: [WebAIM] It's Official - New Sec. 508 is out

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-and-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 ADDRESS REMOVED = .

From: Dona Patrick
Date: Fri, Feb 20 2015 10:20AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

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 ADDRESS 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-and-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 ADDRESS REMOVED = .
>
>
>
>
> > > >

From: Duff Johnson
Date: Fri, Feb 20 2015 10:35AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

Hi Dona,

> 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?

This Rule will not *force* any / every company to use PDF/UA as a standard for PDF documents (or WCAG 2.0 for web pages) unless Section 508 already applied.

The Rule itself could be slightly more clearly stated, IMO, but PDF/UA is required “when applicable”.

On this page

http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/proposed-rule/v-major-issues

The Access Board says:

"The proposed rule would address these deficiencies in the existing 508 Standards by clearly delineating the scope of covered electronic content, as well as specifying concrete, testable, technical requirements to ensure the accessibility of such content. The Board proposes that all covered electronic content would be required to conform to WCAG 2.0 Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages or, where applicable, ISO 14289-1 (PDF/UA-1)."

And two paragraphs further on they give an example:

"The central principle underlying the accessibility requirement for public-facing content is the notion that federal agencies must ensure equal access to electronic information that they themselves directly make available to the general public by posting on a public fora. So, for example, if a federal agency posts a PDF version of a recent settlement agreement on its website as part of a press release, that document would need to comply with PDF/UA-1.”

Duff.

From: Jon Metz
Date: Fri, Feb 20 2015 10:42AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

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 ADDRESS 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 ADDRESS 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-and-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 ADDRESS REMOVED = .
> >
> >
> >
> >
> > > > > > > >
> > > >

From: Chagnon | PubCom
Date: Fri, Feb 20 2015 10:47AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

Katie's correct.
Submit your comments to the Access Board now, not later. I've worked on a
great deal of legislation and rulemaking here in Washington, and comments
that are submitted late in the review period are often too late to be fully
considered and incorporated into the final piece.

State what you don't like, and just as important, what you do like. Here are
links:

The proposed guidelines in HTML and PDF:
http://www.access-board.gov/guidelines-and-standards/communications-and-it/a
bout-the-ict-refresh/proposed-rule

Submit comments here:
http://www.regulations.gov/#!docketDetail;D=ATBCB-2015-0002

--Bevi Chagnon

— — —
Bevi Chagnon | www.PubCom.com
Consultants, Trainers, Designers, and Developers
For publishing technologies
| Acrobat PDF | Digital Media | XML and Automated Workflows
| GPO | Print | Desktop Publishing | Sec. 508 Accessibility | EPUBs
— — —

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Haritos-Shea,
Katie
Sent: Friday, February 20, 2015 12:24 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

This is right and if you really want to ensure that it will stay there - you
need to send in a comment - which they are asking for now - that you like
this and really want it to remain in for the Final Rule.

* katie *
 
Katie Haritos-Shea
Senior Accessibility SME (WCAG/Section 508/ADA), Standards QA Architect JPMC
dCE eCAT: Visit our Digital Accessibility Knowledge Base (DAKB), your source
for JPMC accessibility best practices.

JPMC Digital | Wilmington, DE | = EMAIL ADDRESS REMOVED = | Office:
302-282-1439 | Ext: 21439 | Cell: 703-371-5545 | LinkedIn Profile

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Dona Patrick
Sent: Friday, February 20, 2015 12:20 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

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 ADDRESS 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-an
> d-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 ADDRESS REMOVED = .
>
>
>
>
> > > list messages to = EMAIL ADDRESS REMOVED =
>
messages to = EMAIL ADDRESS REMOVED =

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From: Joseph Feria-Galicia
Date: Fri, Feb 20 2015 10:53AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

Public Comment on the Proposed Rule take place at the CSUN conference
<http://www.csun.edu/cod/conference/2015/sessions/index.php/public/website_pages/view/1>;
on March 5, 9:30 to 11:30. Very strategic.

The Board seeks public comment on the proposed rule as well as a
preliminary assessment of its estimated benefits and costs. The Board
welcomes comment on any aspect of the proposal but is particularly
interested in responses to the more than 40 questions on various topics it
has posed throughout the preamble discussion that accompanies the proposed
text. The rule includes instructions on submitting comments which are due
in 90 days. In addition, the Board will hold public hearings on the
proposed rule that provide another venue for submitting comment:

March 5, 9:30 to 11:30
Manchester Grand Hyatt Hotel, Mission Beach A & B
One Market Place
San Diego, CA

March 11, 9:30 to 11:30
Access Board Conference Center
1331 F Street NW, Suite 800
Washington, DC

On Fri, Feb 20, 2015 at 9:23 AM, Haritos-Shea, Katie <
= EMAIL ADDRESS REMOVED = > wrote:

> This is right and if you really want to ensure that it will stay there -
> you need to send in a comment - which they are asking for now - that you
> like this and really want it to remain in for the Final Rule.
>
> * katie *
>
> Katie Haritos-Shea
> Senior Accessibility SME (WCAG/Section 508/ADA), Standards QA Architect
> JPMC dCE eCAT: Visit our Digital Accessibility Knowledge Base (DAKB), your
> source for JPMC accessibility best practices.
>
> JPMC Digital | Wilmington, DE | = EMAIL ADDRESS REMOVED = | Office:
> 302-282-1439 | Ext: 21439 | Cell: 703-371-5545 | LinkedIn Profile
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto:
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Dona Patrick
> Sent: Friday, February 20, 2015 12:20 PM
> To: WebAIM Discussion List
> Subject: Re: [WebAIM] It's Official - New Sec. 508 is out
>
> 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 ADDRESS 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-an
> > d-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 ADDRESS REMOVED = .
> >
> >
> >
> >
> > > > > > list messages to = EMAIL ADDRESS REMOVED =
> >
> > > messages to = EMAIL ADDRESS REMOVED =
>
> This transmission may contain information that is privileged,
> confidential, legally privileged, and/or exempt from disclosure under
> applicable law. If you are not the intended recipient, you are hereby
> notified that any disclosure, copying, distribution, or use of the
> information contained herein (including any reliance thereon) is STRICTLY
> PROHIBITED. Although this transmission and any attachments are believed to
> be free of any virus or other defect that might affect any computer system
> into which it is received and opened, it is the responsibility of the
> recipient to ensure that it is virus free and no responsibility is accepted
> by JPMorgan Chase & Co., its subsidiaries and affiliates, as applicable,
> for any loss or damage arising in any way from its use. If you received
> this transmission in error, please immediately contact the sender and
> destroy the material in its entirety, whether in electronic or hard copy
> format. Thank you.
> > > >



--
*Instructional Designer*
Berkeley Resource Center for Online Education (BRCOE)
Suite 453C
1995 University Avenue
Berkeley, CA 94710
Phone: 1 510 664-7082
http://online.berkeley.edu

From: Jon Metz
Date: Fri, Feb 20 2015 11:04AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

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 ADDRESS 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 ADDRESS 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 ADDRESS 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-and-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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > >> >
>> >> >> >>
>
>

From: Thomas McKeithan II
Date: Fri, Feb 20 2015 11:26AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

I'm reviewing the rules now. I'm elated that WCAG has been incorporated. I am concerned about the specific reference to v.2.0 given that regulations take a while to change and technology grows expeditiously..

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)
 

This electronic mail (including any attachments) may contain information that is privileged, confidential, and/or otherwise protected from disclosure to anyone other than its intended recipient(s). Any dissemination or use of this electronic email or its contents (including any attachments) by persons other than the intended recipient(s) is strictly prohibited. If you have received this message in error, please notify the sender by reply email and delete the original message (including any attachments) in its entirety.


-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Joseph Feria-Galicia
Sent: Friday, February 20, 2015 12:53 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

Public Comment on the Proposed Rule take place at the CSUN conference
<http://www.csun.edu/cod/conference/2015/sessions/index.php/public/website_pages/view/1>;
on March 5, 9:30 to 11:30. Very strategic.

The Board seeks public comment on the proposed rule as well as a
preliminary assessment of its estimated benefits and costs. The Board
welcomes comment on any aspect of the proposal but is particularly
interested in responses to the more than 40 questions on various topics it
has posed throughout the preamble discussion that accompanies the proposed
text. The rule includes instructions on submitting comments which are due
in 90 days. In addition, the Board will hold public hearings on the
proposed rule that provide another venue for submitting comment:

March 5, 9:30 to 11:30
Manchester Grand Hyatt Hotel, Mission Beach A & B
One Market Place
San Diego, CA

March 11, 9:30 to 11:30
Access Board Conference Center
1331 F Street NW, Suite 800
Washington, DC

On Fri, Feb 20, 2015 at 9:23 AM, Haritos-Shea, Katie <
= EMAIL ADDRESS REMOVED = > wrote:

> This is right and if you really want to ensure that it will stay there -
> you need to send in a comment - which they are asking for now - that you
> like this and really want it to remain in for the Final Rule.
>
> * katie *
>
> Katie Haritos-Shea
> Senior Accessibility SME (WCAG/Section 508/ADA), Standards QA Architect
> JPMC dCE eCAT: Visit our Digital Accessibility Knowledge Base (DAKB), your
> source for JPMC accessibility best practices.
>
> JPMC Digital | Wilmington, DE | = EMAIL ADDRESS REMOVED = | Office:
> 302-282-1439 | Ext: 21439 | Cell: 703-371-5545 | LinkedIn Profile
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto:
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Dona Patrick
> Sent: Friday, February 20, 2015 12:20 PM
> To: WebAIM Discussion List
> Subject: Re: [WebAIM] It's Official - New Sec. 508 is out
>
> 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 ADDRESS 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-an
> > d-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 ADDRESS REMOVED = .
> >
> >
> >
> >
> > > > > > list messages to = EMAIL ADDRESS REMOVED =
> >
> > > messages to = EMAIL ADDRESS REMOVED =
>
> This transmission may contain information that is privileged,
> confidential, legally privileged, and/or exempt from disclosure under
> applicable law. If you are not the intended recipient, you are hereby
> notified that any disclosure, copying, distribution, or use of the
> information contained herein (including any reliance thereon) is STRICTLY
> PROHIBITED. Although this transmission and any attachments are believed to
> be free of any virus or other defect that might affect any computer system
> into which it is received and opened, it is the responsibility of the
> recipient to ensure that it is virus free and no responsibility is accepted
> by JPMorgan Chase & Co., its subsidiaries and affiliates, as applicable,
> for any loss or damage arising in any way from its use. If you received
> this transmission in error, please immediately contact the sender and
> destroy the material in its entirety, whether in electronic or hard copy
> format. Thank you.
> > > >



--
*Instructional Designer*
Berkeley Resource Center for Online Education (BRCOE)
Suite 453C
1995 University Avenue
Berkeley, CA 94710
Phone: 1 510 664-7082
http://online.berkeley.edu

From: Chagnon | PubCom
Date: Fri, Feb 20 2015 11:33AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to = EMAIL ADDRESS REMOVED =
>> >
>> >> >> list messages to = EMAIL ADDRESS REMOVED =
>>
>
>
messages to = EMAIL ADDRESS REMOVED =

From: Katie Haritos-Shea GMAIL
Date: Fri, Feb 20 2015 11:38AM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to = EMAIL ADDRESS REMOVED =
>> >
>> >> >> list messages to = EMAIL ADDRESS REMOVED =
>>
>
>
messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

From: Chagnon | PubCom
Date: Fri, Feb 20 2015 12:07PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to = EMAIL ADDRESS REMOVED =
>> >
>> >> >> list messages to = EMAIL ADDRESS REMOVED =
>>
>
>
messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

From: Joy Relton
Date: Fri, Feb 20 2015 12:14PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

Oh Bevi,

This is theworldof the FederalGovernment. The wheels grindslowly, but, they
are



Joy Reltongrinding.
Accessibility Consultant
Deque Systems

703-225-0380
= EMAIL ADDRESS REMOVED =
= EMAIL ADDRESS REMOVED =

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to = EMAIL ADDRESS REMOVED =
>> >
>> >> >> list messages to = EMAIL ADDRESS REMOVED =
>>
>
>
messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

From: Thomas McKeithan II
Date: Fri, Feb 20 2015 12:15PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

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)
 

This electronic mail (including any attachments) may contain information that is privileged, confidential, and/or otherwise protected from disclosure to anyone other than its intended recipient(s). Any dissemination or use of this electronic email or its contents (including any attachments) by persons other than the intended recipient(s) is strictly prohibited. If you have received this message in error, please notify the sender by reply email and delete the original message (including any attachments) in its entirety.



-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to = EMAIL ADDRESS REMOVED =
>> >
>> >> >> list messages to = EMAIL ADDRESS REMOVED =
>>
>
>
messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

From: Katie Haritos-Shea GMAIL
Date: Fri, Feb 20 2015 12:38PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

The exact place where you can find this responsibility given to the Access
Board to update the standards is in the law...

Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794
(d))

§ 794d. Electronic and information technology

" (B) Review and amendment

The Access Board shall periodically review and, as appropriate, amend the
standards required under subparagraph (A) to reflect technological advances
or changes in electronic and information technology."

You can find the law in many places, but it is also on the Access Board site
at:
http://www.access-board.gov/guidelines-and-standards/communications-and-it/a
bout-the-section-508-standards/background/section-508-the-law

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

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to = EMAIL ADDRESS REMOVED =
>> >
>> >> >> list messages to = EMAIL ADDRESS REMOVED =
>>
>
>
messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

From: Chagnon | PubCom
Date: Fri, Feb 20 2015 12:53PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

Triannual assessment ... that's 3 times per year, review the existing
standards.
For, maybe, seeing how well the current standards are keeping up with
technologies, and also how well they mesh with WCAG, PDF/UA, and possibly
other standards?
Or do you mean the "board" that meets now every other month to do whatever
its functions currently are?
Just trying to clarify what you mean, that's all!

--Bevi Chagnon

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Thomas McKeithan
II
Sent: Friday, February 20, 2015 2:15 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

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)
 

This electronic mail (including any attachments) may contain information
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this electronic email or its contents (including any attachments) by persons
other than the intended recipient(s) is strictly prohibited. If you have
received this message in error, please notify the sender by reply email and
delete the original message (including any attachments) in its entirety.



-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to = EMAIL ADDRESS REMOVED =
>> >
>> >> >> list messages to = EMAIL ADDRESS REMOVED =
>>
>
>
messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =

messages to = EMAIL ADDRESS REMOVED =
messages to = EMAIL ADDRESS REMOVED =

From: Chagnon | PubCom
Date: Fri, Feb 20 2015 1:08PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

Thanks, Katie.
But that's the law, not the Access Board's policy.
Congress write laws with a very broad brush, with few specific details so
that the agency that regulates/maintains/enforces the law can tweak its
policies as needed without going to Capitol Hill. (Oh god, save us from
doing that!)

So the law specifies that the Access Board must review and amend the
standards "periodically," but the law doesn't define periodically or put any
more specific time deadlines on the Board's actions.

My question is, still, how does the Access Board define "periodically?"
What's in their policies? Is there anything in their policies (and operating
procedures) that states how quickly they will address changes in standards
and technology? Do they have a workflow, timeline, milestones, etc. for
doing this? Are the policies (or a summary of them) available on the
website? I don't see any.

I work with other government agencies in these areas so I know it's possible
for an agency to set these policies. It's not out of the question.

Right now we're hearing listmembers say, holy cannoli, are we going to wait
another 6.5 years before WCAG 3 is accepted? So far, we don't have a good
answer to that question.

--Bevi Chagnon

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Katie
Haritos-Shea GMAIL
Sent: Friday, February 20, 2015 2:39 PM
To: 'WebAIM Discussion List'
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

The exact place where you can find this responsibility given to the Access
Board to update the standards is in the law...

Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794
(d))

§ 794d. Electronic and information technology

" (B) Review and amendment

The Access Board shall periodically review and, as appropriate, amend the
standards required under subparagraph (A) to reflect technological advances
or changes in electronic and information technology."

You can find the law in many places, but it is also on the Access Board site
at:
http://www.access-board.gov/guidelines-and-standards/communications-and-it/a
bout-the-section-508-standards/background/section-508-the-law

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

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .

From: Katie Haritos-Shea GMAIL
Date: Fri, Feb 20 2015 2:11PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

You might want to ask the Access Board themselves, I do not have any idea as
to what their internal policies are......and again, keep in mind it is a
very small agency.



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

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Chagnon | PubCom
Sent: Friday, February 20, 2015 3:08 PM
To: 'WebAIM Discussion List'
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

Thanks, Katie.
But that's the law, not the Access Board's policy.
Congress write laws with a very broad brush, with few specific details so
that the agency that regulates/maintains/enforces the law can tweak its
policies as needed without going to Capitol Hill. (Oh god, save us from
doing that!)

So the law specifies that the Access Board must review and amend the
standards "periodically," but the law doesn't define periodically or put any
more specific time deadlines on the Board's actions.

My question is, still, how does the Access Board define "periodically?"
What's in their policies? Is there anything in their policies (and operating
procedures) that states how quickly they will address changes in standards
and technology? Do they have a workflow, timeline, milestones, etc. for
doing this? Are the policies (or a summary of them) available on the
website? I don't see any.

I work with other government agencies in these areas so I know it's possible
for an agency to set these policies. It's not out of the question.

Right now we're hearing listmembers say, holy cannoli, are we going to wait
another 6.5 years before WCAG 3 is accepted? So far, we don't have a good
answer to that question.

--Bevi Chagnon

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Katie
Haritos-Shea GMAIL
Sent: Friday, February 20, 2015 2:39 PM
To: 'WebAIM Discussion List'
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

The exact place where you can find this responsibility given to the Access
Board to update the standards is in the law...

Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794
(d))

§ 794d. Electronic and information technology

" (B) Review and amendment

The Access Board shall periodically review and, as appropriate, amend the
standards required under subparagraph (A) to reflect technological advances
or changes in electronic and information technology."

You can find the law in many places, but it is also on the Access Board site
at:
http://www.access-board.gov/guidelines-and-standards/communications-and-it/a
bout-the-section-508-standards/background/section-508-the-law

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

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .

messages to = EMAIL ADDRESS REMOVED =

From: Dona Patrick
Date: Fri, Feb 20 2015 3:14PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

Thanks Duff -- we are bound by Section 508 on our US Government contracts
-- so it applies what we do.

On Fri, Feb 20, 2015 at 12:35 PM, Duff Johnson < = EMAIL ADDRESS REMOVED = >
wrote:

> Hi Dona,
>
> > 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?
>
> This Rule will not *force* any / every company to use PDF/UA as a standard
> for PDF documents (or WCAG 2.0 for web pages) unless Section 508 already
> applied.
>
> The Rule itself could be slightly more clearly stated, IMO, but PDF/UA is
> required “when applicable”.
>
> On this page
>
>
> http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/proposed-rule/v-major-issues
>
> The Access Board says:
>
> "The proposed rule would address these deficiencies in the existing 508
> Standards by clearly delineating the scope of covered electronic content,
> as well as specifying concrete, testable, technical requirements to ensure
> the accessibility of such content. The Board proposes that all covered
> electronic content would be required to conform to WCAG 2.0 Level A and
> Level AA Success Criteria and Conformance Requirements specified for Web
> pages or, where applicable, ISO 14289-1 (PDF/UA-1)."
>
> And two paragraphs further on they give an example:
>
> "The central principle underlying the accessibility requirement for
> public-facing content is the notion that federal agencies must ensure equal
> access to electronic information that they themselves directly make
> available to the general public by posting on a public fora. So, for
> example, if a federal agency posts a PDF version of a recent settlement
> agreement on its website as part of a press release, that document would
> need to comply with PDF/UA-1.”
>
> Duff.
> > > >

From: Ron
Date: Fri, Feb 20 2015 3:52PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

In following this thread there is an important distinction to be made the
NPRM has been released. If you have issues or recomendations to make you
have your chance, and need to get your comments submitted.

Once this period has ended we will then go into the final rule making
process, and once the Final Rules have been published the Access Board will
develop the implimentation regulations and guidance.

That process will take some time ~18 months is the average the last time I
looked. This is your only opportunity to provide imput to the final
product and it does impact the final product and subsequent administrative
rules.

Ron Stewart

On Friday, February 20, 2015, Dona Patrick < = EMAIL ADDRESS REMOVED = > wrote:

> Thanks Duff -- we are bound by Section 508 on our US Government contracts
> -- so it applies what we do.
>
> On Fri, Feb 20, 2015 at 12:35 PM, Duff Johnson < = EMAIL ADDRESS REMOVED =
> <javascript:;>>
> wrote:
>
> > Hi Dona,
> >
> > > 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?
> >
> > This Rule will not *force* any / every company to use PDF/UA as a
> standard
> > for PDF documents (or WCAG 2.0 for web pages) unless Section 508 already
> > applied.
> >
> > The Rule itself could be slightly more clearly stated, IMO, but PDF/UA is
> > required “when applicable”.
> >
> > On this page
> >
> >
> >
> http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/proposed-rule/v-major-issues
> >
> > The Access Board says:
> >
> > "The proposed rule would address these deficiencies in the existing 508
> > Standards by clearly delineating the scope of covered electronic content,
> > as well as specifying concrete, testable, technical requirements to
> ensure
> > the accessibility of such content. The Board proposes that all covered
> > electronic content would be required to conform to WCAG 2.0 Level A and
> > Level AA Success Criteria and Conformance Requirements specified for Web
> > pages or, where applicable, ISO 14289-1 (PDF/UA-1)."
> >
> > And two paragraphs further on they give an example:
> >
> > "The central principle underlying the accessibility requirement for
> > public-facing content is the notion that federal agencies must ensure
> equal
> > access to electronic information that they themselves directly make
> > available to the general public by posting on a public fora. So, for
> > example, if a federal agency posts a PDF version of a recent settlement
> > agreement on its website as part of a press release, that document would
> > need to comply with PDF/UA-1.”
> >
> > Duff.
> > > > > > > >
> > > >

From: Ryan E. Benson
Date: Fri, Feb 20 2015 4:24PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

>Technically it has been up to whether the Section 508 Coordinator Offices
considered PDFs are considered EIT or not.

Most of the Coordinators I know, believe that PDFs are considered to fall
under 508. The challenge is /how/ to evaluate it. Most acknowledge that if
a PDF is on a website, or distributed electronically, it falls under
1194.41. This says documentation needs to be available in other formats.
Another connection is made is if any of the technically standards
(1194.21-.26) then the functional (1194.31) and the Information,
documentation, and support (1194.41) standards apply by default. By
correlation, if 1194.41 apply then 1194.31 does - which say things have to
work for various types of disabilities and the AT they may use. This is
where the hang up occurs. There is not thing to point to. The web
standards (1194.22) are pointed to from here, but they aren't a clean fit.


--
Ryan E. Benson

On Fri, Feb 20, 2015 at 12:42 PM, Jon Metz < = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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-and-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 ADDRESS REMOVED = .
> > >
> > >
> > >
> > >
> > > > > > > > > > > >
> > > > > > > >
> > > >

From: Greg Gamble
Date: Fri, Feb 20 2015 4:37PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | Next message →

I'd be real careful about this one. When working with standards you want them written in concrete ... you don't want to read it one week and then find out it's different the next week. I've dealt with standards in the machining industry, and standards that are even the least bit open to discussion are trouble waiting to happen. Imagine the PDF standard being updated only to find it breaks current layouts ... better to lock down to what is current and works, then to open up to something unknown. JMO

Greg

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jon Metz
Sent: Friday, February 20, 2015 10:04 AM
To: WebAIM Discussion List
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

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

Thanks!
Jon Metz

From: Thomas McKeithan II
Date: Fri, Feb 20 2015 6:46PM
Subject: Re: It's Official - New Sec. 508 is out
← Previous message | No next message

I mean assess the standards and the evolution of technology at a minimum of every three years and refresh those portions that have become obsolete.

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 ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Chagnon | PubCom
Sent: Friday, February 20, 2015 2:54 PM
To: 'WebAIM Discussion List'
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

Triannual assessment ... that's 3 times per year, review the existing standards.
For, maybe, seeing how well the current standards are keeping up with technologies, and also how well they mesh with WCAG, PDF/UA, and possibly other standards?
Or do you mean the "board" that meets now every other month to do whatever its functions currently are?
Just trying to clarify what you mean, that's all!

--Bevi Chagnon

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Thomas McKeithan II
Sent: Friday, February 20, 2015 2:15 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] It's Official - New Sec. 508 is out

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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED = | Oakton, VA | LinkedIn Profile |
Office: 703-371-5545

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS 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 ADDRESS REMOVED = .
>> >
>> >
>> >
>> >
>> > >> > >> > list messages to = EMAIL ADDRESS REMOVED =
>> >
>> >> >> list messages to = EMAIL ADDRESS REMOVED =
>>
>
>