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Thread: VPATs for Word, PPT, Excel, etc

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Number of posts in this thread: 19 (In chronological order)

From: Emily Ogle
Date: Fri, Jun 01 2018 2:24PM
Subject: VPATs for Word, PPT, Excel, etc
No previous message | Next message →

Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc, when providing deliverables to the government?

From: chagnon@pubcom.com
Date: Fri, Jun 01 2018 2:47PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

No.
VPAT has the word "Voluntary" in it, which to me means "whatever you want."

The government would be better served if they required certification of documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any of our free or not-so-free tools such as:

Acrobat Pro DC:2018
Word and PowerPoint built-in checker
Axes 4
PAC-3
NetCentric's Validator

Generally, we find that if the file passes any combo of two of these, then it's usually ok, but of course, the best testing is done my knowledgeable humans!

--Bevi Chagnon

— — —
Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
— — —
PubCom: Technologists for Accessible Design + Publishing
consulting • training • development • design • sec. 508 services
Upcoming classes at www.PubCom.com/classes
— — —


-----Original Message-----
From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of Emily Ogle via WebAIM-Forum
Sent: Friday, June 1, 2018 4:24 PM
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Subject: [WebAIM] VPATs for Word, PPT, Excel, etc

Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc, when providing deliverables to the government?

From: Patrick H. Lauke
Date: Fri, Jun 01 2018 2:51PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

On 01/06/2018 21:47, = EMAIL ADDRESS REMOVED = wrote:
> No.
> VPAT has the word "Voluntary" in it, which to me means "whatever you want."
>
> The government would be better served if they required certification of documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).

VPAT 2.0 incorporates WCAG 2.0 ...

P
--
Patrick H. Lauke

www.splintered.co.uk | https://github.com/patrickhlauke
http://flickr.com/photos/redux/ | http://redux.deviantart.com
twitter: @patrick_h_lauke | skype: patrick_h_lauke

From: Jonathan Avila
Date: Fri, Jun 01 2018 7:35PM
Subject: Re: VPATs for Word, PPT, Excel, etc
← Previous message | Next message →

The revised Section 508 standards more clearly cover non-web electronic documents including public and 9 types of non-public documents. VPAT 2.x which includes the WCAG 2 criteria referenced by Section 508 specifically have designated line items for indicating the level of support for electronic documents for each success criteria. Generally electronic documents listed in VPATs are those associated with a product or service. However this does not have to be the case. A government agency could ask for a VPAT for any ICT including electronic documents.

Asking for a VPAT for each document does seem a little bit much and while I agree there are certainly better ways it is a reasonable ask in particular for complex or long documents. With any VPAT the information provided may not accurately describe the level of support for any ICT and the results should be backed up by test results. A clean automated test checklist is a start toward automating that process but in itself does not fully address all of the requirements.

Jonathan

Jonathan Avila
Chief Accessibility Officer
Level Access
= EMAIL ADDRESS REMOVED =
703.637.8957 office

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-----Original Message-----
From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of Emily Ogle via WebAIM-Forum
Sent: Friday, June 1, 2018 4:24 PM
To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
Subject: [WebAIM] VPATs for Word, PPT, Excel, etc

Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc, when providing deliverables to the government?

From: Ryan E. Benson
Date: Fri, Jun 01 2018 8:25PM
Subject: Re: VPATs for Word, PPT, Excel, etc
← Previous message | Next message →

This is normal for HHS agencies, and some other Departmennts. While a VPAT
is a little overkill for the file types mentioned, agencies often have a
checklist for those which is used in place of a VPAT. HHS' are located at:
https://www.hhs.gov/web/section-508/making-files-accessible/index.html. I
would recommend asking your COR if they have similar checklists, or ask to
talk to the agency 508 Coordinator if the COR dioesn't know.

--
Ryan E. Benson

On Fri, Jun 1, 2018 at 4:24 PM, Emily Ogle via WebAIM-Forum <
= EMAIL ADDRESS REMOVED = > wrote:

> Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc,
> when providing deliverables to the government?
> > > > >

From: Ryan E. Benson
Date: Fri, Jun 01 2018 8:49PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

> VPAT has the word "Voluntary" in it, which to me means "whatever you
want."

This is incorrect. Yes the V is for voluntary, meaning "here's the
documentation without asking for it." If the government asks, you either
provide the PAT or risk losing the contract. The company is still able to
deny the request, but it's not in your best interest. In terms of Emily's
question, contract language [often] says provide a VPAT for all
deliverables. The checklists I mentioned are an alternative to a VPAT for
docs. These are often written in non-legalese to make things easier.

> The government would be better served if they required certification of
documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).

A VPAT is literally just that. It is a document that says "We, [company],
certify our deliverable meets these standards." As an example, HHS' has

d) Respondents to this solicitation must identify any exception to Section
508 requirements. If a offeror claims its supplies or services meet
applicable Section 508 accessibility standards, and it is later determined
by the Government, i.e., after award of a contract or order, that supplies
or services delivered do not conform to the described accessibility
standards, remediation of the supplies or services to the level of
conformance specified in the contract will be the responsibility of the
Contractor at its expense.

Source:
https://www.hhs.gov/grants/contracts/contract-policies-regulations/hhsar/part-352-solicitation-provisions-contract-clauses/index.html#352.239-73

In English, vendors must document their deliverables meet HHS' standards,
the government reserves the right to double check, and if the government
finds issues prior to acceptance, the vendor must fix it. GSA has some
high-level guidance to develop language like I quoted above at:
https://section508.gov/buy/define-accessibility-criteria.

--
Ryan E. Benson

On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:

> No.
> VPAT has the word "Voluntary" in it, which to me means "whatever you want."
>
> The government would be better served if they required certification of
> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any of our
> free or not-so-free tools such as:
>
> Acrobat Pro DC:2018
> Word and PowerPoint built-in checker
> Axes 4
> PAC-3
> NetCentric's Validator
>
> Generally, we find that if the file passes any combo of two of these, then
> it's usually ok, but of course, the best testing is done my knowledgeable
> humans!
>
> --Bevi Chagnon
>
> — — —
> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
> — — —
> PubCom: Technologists for Accessible Design + Publishing
> consulting • training • development • design • sec. 508 services
> Upcoming classes at www.PubCom.com/classes
> — — —
>
>
> -----Original Message-----
> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
> Emily Ogle via WebAIM-Forum
> Sent: Friday, June 1, 2018 4:24 PM
> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
>
> Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc,
> when providing deliverables to the government?
> > > at http://webaim.org/discussion/archives
> >
> > > > >

From: Duff Johnson
Date: Sat, Jun 02 2018 10:02AM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

So, looking for clarity here…

a) Is it reasonable or plausible that an agency might demand a VPAT for each deliverable?

b) Is it reasonable to expect that “deliverable” can be construed to include documents?

c) That while the form of the VPAT must be explicable, the actual nature of the VPAT itself, on a per-document basis, is up to the agency (vendor, whatever), providing the document under terms that include a VPAT….yes? Seems obvious, but always best to ask.

If all of these are true I have a follow-up question.

Thanks.

Duff.

> On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = > wrote:
>
>> VPAT has the word "Voluntary" in it, which to me means "whatever you
> want."
>
> This is incorrect. Yes the V is for voluntary, meaning "here's the
> documentation without asking for it." If the government asks, you either
> provide the PAT or risk losing the contract. The company is still able to
> deny the request, but it's not in your best interest. In terms of Emily's
> question, contract language [often] says provide a VPAT for all
> deliverables. The checklists I mentioned are an alternative to a VPAT for
> docs. These are often written in non-legalese to make things easier.
>
>> The government would be better served if they required certification of
> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
>
> A VPAT is literally just that. It is a document that says "We, [company],
> certify our deliverable meets these standards." As an example, HHS' has
>
> d) Respondents to this solicitation must identify any exception to Section
> 508 requirements. If a offeror claims its supplies or services meet
> applicable Section 508 accessibility standards, and it is later determined
> by the Government, i.e., after award of a contract or order, that supplies
> or services delivered do not conform to the described accessibility
> standards, remediation of the supplies or services to the level of
> conformance specified in the contract will be the responsibility of the
> Contractor at its expense.
>
> Source:
> https://www.hhs.gov/grants/contracts/contract-policies-regulations/hhsar/part-352-solicitation-provisions-contract-clauses/index.html#352.239-73
>
> In English, vendors must document their deliverables meet HHS' standards,
> the government reserves the right to double check, and if the government
> finds issues prior to acceptance, the vendor must fix it. GSA has some
> high-level guidance to develop language like I quoted above at:
> https://section508.gov/buy/define-accessibility-criteria.
>
> --
> Ryan E. Benson
>
> On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
>
>> No.
>> VPAT has the word "Voluntary" in it, which to me means "whatever you want."
>>
>> The government would be better served if they required certification of
>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any of our
>> free or not-so-free tools such as:
>>
>> Acrobat Pro DC:2018
>> Word and PowerPoint built-in checker
>> Axes 4
>> PAC-3
>> NetCentric's Validator
>>
>> Generally, we find that if the file passes any combo of two of these, then
>> it's usually ok, but of course, the best testing is done my knowledgeable
>> humans!
>>
>> --Bevi Chagnon
>>
>> — — —
>> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
>> — — —
>> PubCom: Technologists for Accessible Design + Publishing
>> consulting • training • development • design • sec. 508 services
>> Upcoming classes at www.PubCom.com/classes
>> — — —
>>
>>
>> -----Original Message-----
>> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
>> Emily Ogle via WebAIM-Forum
>> Sent: Friday, June 1, 2018 4:24 PM
>> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
>> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
>>
>> Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc,
>> when providing deliverables to the government?
>> >> >> at http://webaim.org/discussion/archives
>> >>
>> >> >> >> >>
> > > >

From: Emily Ogle
Date: Sat, Jun 02 2018 5:46PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

Well, it would seem it is entirely plausible an agency would insist on a VPAT for each deliverable, eg, Word, PPT, etc, because that’s happened.

This is unexpected so I’m looking to find out what they’re really expecting since we’d have to rethink our strategy by quite a bit. When I asked the DHS what the typical expectation was, I was given a link to the trusted tester page, in which there was, among several files, an 84-page document on how to test Word files for accessibility!

We’re providing training on how to make PPTs etc accessible, but a VPAT for each seems like overkill.

> On Jun 2, 2018, at 11:02 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:
>
> So, looking for clarity here…
>
> a) Is it reasonable or plausible that an agency might demand a VPAT for each deliverable?
>
> b) Is it reasonable to expect that “deliverable” can be construed to include documents?
>
> c) That while the form of the VPAT must be explicable, the actual nature of the VPAT itself, on a per-document basis, is up to the agency (vendor, whatever), providing the document under terms that include a VPAT….yes? Seems obvious, but always best to ask.
>
> If all of these are true I have a follow-up question.
>
> Thanks.
>
> Duff.
>
>>> On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = > wrote:
>>>
>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
>> want."
>>
>> This is incorrect. Yes the V is for voluntary, meaning "here's the
>> documentation without asking for it." If the government asks, you either
>> provide the PAT or risk losing the contract. The company is still able to
>> deny the request, but it's not in your best interest. In terms of Emily's
>> question, contract language [often] says provide a VPAT for all
>> deliverables. The checklists I mentioned are an alternative to a VPAT for
>> docs. These are often written in non-legalese to make things easier.
>>
>>> The government would be better served if they required certification of
>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
>>
>> A VPAT is literally just that. It is a document that says "We, [company],
>> certify our deliverable meets these standards." As an example, HHS' has
>>
>> d) Respondents to this solicitation must identify any exception to Section
>> 508 requirements. If a offeror claims its supplies or services meet
>> applicable Section 508 accessibility standards, and it is later determined
>> by the Government, i.e., after award of a contract or order, that supplies
>> or services delivered do not conform to the described accessibility
>> standards, remediation of the supplies or services to the level of
>> conformance specified in the contract will be the responsibility of the
>> Contractor at its expense.
>>
>> Source:
>> https://www.hhs.gov/grants/contracts/contract-policies-regulations/hhsar/part-352-solicitation-provisions-contract-clauses/index.html#352.239-73
>>
>> In English, vendors must document their deliverables meet HHS' standards,
>> the government reserves the right to double check, and if the government
>> finds issues prior to acceptance, the vendor must fix it. GSA has some
>> high-level guidance to develop language like I quoted above at:
>> https://section508.gov/buy/define-accessibility-criteria.
>>
>> --
>> Ryan E. Benson
>>
>>> On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
>>>
>>> No.
>>> VPAT has the word "Voluntary" in it, which to me means "whatever you want."
>>>
>>> The government would be better served if they required certification of
>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any of our
>>> free or not-so-free tools such as:
>>>
>>> Acrobat Pro DC:2018
>>> Word and PowerPoint built-in checker
>>> Axes 4
>>> PAC-3
>>> NetCentric's Validator
>>>
>>> Generally, we find that if the file passes any combo of two of these, then
>>> it's usually ok, but of course, the best testing is done my knowledgeable
>>> humans!
>>>
>>> --Bevi Chagnon
>>>
>>> — — —
>>> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
>>> — — —
>>> PubCom: Technologists for Accessible Design + Publishing
>>> consulting • training • development • design • sec. 508 services
>>> Upcoming classes at www.PubCom.com/classes
>>> — — —
>>>
>>>
>>> -----Original Message-----
>>> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
>>> Emily Ogle via WebAIM-Forum
>>> Sent: Friday, June 1, 2018 4:24 PM
>>> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
>>> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
>>>
>>> Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc,
>>> when providing deliverables to the government?
>>> >>> >>> at http://webaim.org/discussion/archives
>>> >>>
>>> >>> >>> >>> >>>
>> >> >> >> >
> > > >

From: Jonathan Avila
Date: Mon, Jun 04 2018 7:38AM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

> This is unexpected so I’m looking to find out what they’re really expecting since we’d have to rethink our strategy by quite a bit. When I asked the DHS what the typical expectation was, I was given a link to the trusted tester page, in which there was, among several files, an 84-page document on how to test Word files for accessibility!

There is an accompanying results spreadsheet for the trusted tester process that is to be completed by the Trusted Tester. This spreadsheet doesn't appear to be available on the public site but is available on a site that is for people who have passed the Trusted Tester Certification process. It would document all of the items necessary to understand the compliance of the document although not in the same form as a VPAT. As others have mentioned many agencies including HHS and VA have their own checklists and processes and an agency may ask you to complete their documentation in the format/wording that they prefer to have.

Jonathan

-----Original Message-----
From: WebAIM-Forum [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Emily Ogle via WebAIM-Forum
Sent: Saturday, June 02, 2018 7:47 PM
To: WebAIM Discussion List
Subject: Re: [WebAIM] VPATs for Word, PPT, Excel, etc.

Well, it would seem it is entirely plausible an agency would insist on a VPAT for each deliverable, eg, Word, PPT, etc, because that’s happened.

This is unexpected so I’m looking to find out what they’re really expecting since we’d have to rethink our strategy by quite a bit. When I asked the DHS what the typical expectation was, I was given a link to the trusted tester page, in which there was, among several files, an 84-page document on how to test Word files for accessibility!

We’re providing training on how to make PPTs etc accessible, but a VPAT for each seems like overkill.

> On Jun 2, 2018, at 11:02 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:
>
> So, looking for clarity here…
>
> a) Is it reasonable or plausible that an agency might demand a VPAT for each deliverable?
>
> b) Is it reasonable to expect that “deliverable” can be construed to include documents?
>
> c) That while the form of the VPAT must be explicable, the actual nature of the VPAT itself, on a per-document basis, is up to the agency (vendor, whatever), providing the document under terms that include a VPAT….yes? Seems obvious, but always best to ask.
>
> If all of these are true I have a follow-up question.
>
> Thanks.
>
> Duff.
>
>>> On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = > wrote:
>>>
>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
>> want."
>>
>> This is incorrect. Yes the V is for voluntary, meaning "here's the
>> documentation without asking for it." If the government asks, you either
>> provide the PAT or risk losing the contract. The company is still able to
>> deny the request, but it's not in your best interest. In terms of Emily's
>> question, contract language [often] says provide a VPAT for all
>> deliverables. The checklists I mentioned are an alternative to a VPAT for
>> docs. These are often written in non-legalese to make things easier.
>>
>>> The government would be better served if they required certification of
>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
>>
>> A VPAT is literally just that. It is a document that says "We, [company],
>> certify our deliverable meets these standards." As an example, HHS' has
>>
>> d) Respondents to this solicitation must identify any exception to Section
>> 508 requirements. If a offeror claims its supplies or services meet
>> applicable Section 508 accessibility standards, and it is later determined
>> by the Government, i.e., after award of a contract or order, that supplies
>> or services delivered do not conform to the described accessibility
>> standards, remediation of the supplies or services to the level of
>> conformance specified in the contract will be the responsibility of the
>> Contractor at its expense.
>>
>> Source:
>> https://www.hhs.gov/grants/contracts/contract-policies-regulations/hhsar/part-352-solicitation-provisions-contract-clauses/index.html#352.239-73
>>
>> In English, vendors must document their deliverables meet HHS' standards,
>> the government reserves the right to double check, and if the government
>> finds issues prior to acceptance, the vendor must fix it. GSA has some
>> high-level guidance to develop language like I quoted above at:
>> https://section508.gov/buy/define-accessibility-criteria.
>>
>> --
>> Ryan E. Benson
>>
>>> On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
>>>
>>> No.
>>> VPAT has the word "Voluntary" in it, which to me means "whatever you want."
>>>
>>> The government would be better served if they required certification of
>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any of our
>>> free or not-so-free tools such as:
>>>
>>> Acrobat Pro DC:2018
>>> Word and PowerPoint built-in checker
>>> Axes 4
>>> PAC-3
>>> NetCentric's Validator
>>>
>>> Generally, we find that if the file passes any combo of two of these, then
>>> it's usually ok, but of course, the best testing is done my knowledgeable
>>> humans!
>>>
>>> --Bevi Chagnon
>>>
>>> — — —
>>> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
>>> — — —
>>> PubCom: Technologists for Accessible Design + Publishing
>>> consulting • training • development • design • sec. 508 services
>>> Upcoming classes at www.PubCom.com/classes
>>> — — —
>>>
>>>
>>> -----Original Message-----
>>> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
>>> Emily Ogle via WebAIM-Forum
>>> Sent: Friday, June 1, 2018 4:24 PM
>>> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
>>> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
>>>
>>> Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc,
>>> when providing deliverables to the government?
>>> >>> >>> at http://webaim.org/discussion/archives
>>> >>>
>>> >>> >>> >>> >>>
>> >> >> >> >
> > > >

From: Duff Johnson
Date: Mon, Jun 04 2018 10:29AM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

So… my take-away thus far is that agencies can set any expectations for VPATs (or not) that they want.

Next question is for those providing services, specifically, testing/remediation of PDF documents:

Do you use the PDF/UA flag as part of your deliverable?

Based on what I’m hearing it seems like it would be very handy to have a machine-readable indicator that applies to each individual deliverable file, as the file would then contain its own certification.

The service-provider could then simply state that when they apply the PDF/UA flag it is their indication that the file has passed tests for Section 508 conformance.

Of course, it's on the agency adding the flag to ensure that the file conforms to WCAG 2.0 Level AA (assuming that’s what applicable in a given scenario) as well as PDF/UA, but if you are already doing the latter the former should be no big deal.

I’m curious to hear any reactions (positive or negative)...

Duff.


> On Jun 4, 2018, at 09:38, Jonathan Avila < = EMAIL ADDRESS REMOVED = > wrote:
>
>> This is unexpected so I’m looking to find out what they’re really expecting since we’d have to rethink our strategy by quite a bit. When I asked the DHS what the typical expectation was, I was given a link to the trusted tester page, in which there was, among several files, an 84-page document on how to test Word files for accessibility!
>
> There is an accompanying results spreadsheet for the trusted tester process that is to be completed by the Trusted Tester. This spreadsheet doesn't appear to be available on the public site but is available on a site that is for people who have passed the Trusted Tester Certification process. It would document all of the items necessary to understand the compliance of the document although not in the same form as a VPAT. As others have mentioned many agencies including HHS and VA have their own checklists and processes and an agency may ask you to complete their documentation in the format/wording that they prefer to have.
>
> Jonathan
>
> -----Original Message-----
> From: WebAIM-Forum [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Emily Ogle via WebAIM-Forum
> Sent: Saturday, June 02, 2018 7:47 PM
> To: WebAIM Discussion List
> Subject: Re: [WebAIM] VPATs for Word, PPT, Excel, etc.
>
> Well, it would seem it is entirely plausible an agency would insist on a VPAT for each deliverable, eg, Word, PPT, etc, because that’s happened.
>
> This is unexpected so I’m looking to find out what they’re really expecting since we’d have to rethink our strategy by quite a bit. When I asked the DHS what the typical expectation was, I was given a link to the trusted tester page, in which there was, among several files, an 84-page document on how to test Word files for accessibility!
>
> We’re providing training on how to make PPTs etc accessible, but a VPAT for each seems like overkill.
>
>> On Jun 2, 2018, at 11:02 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:
>>
>> So, looking for clarity here…
>>
>> a) Is it reasonable or plausible that an agency might demand a VPAT for each deliverable?
>>
>> b) Is it reasonable to expect that “deliverable” can be construed to include documents?
>>
>> c) That while the form of the VPAT must be explicable, the actual nature of the VPAT itself, on a per-document basis, is up to the agency (vendor, whatever), providing the document under terms that include a VPAT….yes? Seems obvious, but always best to ask.
>>
>> If all of these are true I have a follow-up question.
>>
>> Thanks.
>>
>> Duff.
>>
>>>> On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = > wrote:
>>>>
>>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
>>> want."
>>>
>>> This is incorrect. Yes the V is for voluntary, meaning "here's the
>>> documentation without asking for it." If the government asks, you either
>>> provide the PAT or risk losing the contract. The company is still able to
>>> deny the request, but it's not in your best interest. In terms of Emily's
>>> question, contract language [often] says provide a VPAT for all
>>> deliverables. The checklists I mentioned are an alternative to a VPAT for
>>> docs. These are often written in non-legalese to make things easier.
>>>
>>>> The government would be better served if they required certification of
>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
>>>
>>> A VPAT is literally just that. It is a document that says "We, [company],
>>> certify our deliverable meets these standards." As an example, HHS' has
>>>
>>> d) Respondents to this solicitation must identify any exception to Section
>>> 508 requirements. If a offeror claims its supplies or services meet
>>> applicable Section 508 accessibility standards, and it is later determined
>>> by the Government, i.e., after award of a contract or order, that supplies
>>> or services delivered do not conform to the described accessibility
>>> standards, remediation of the supplies or services to the level of
>>> conformance specified in the contract will be the responsibility of the
>>> Contractor at its expense.
>>>
>>> Source:
>>> https://www.hhs.gov/grants/contracts/contract-policies-regulations/hhsar/part-352-solicitation-provisions-contract-clauses/index.html#352.239-73
>>>
>>> In English, vendors must document their deliverables meet HHS' standards,
>>> the government reserves the right to double check, and if the government
>>> finds issues prior to acceptance, the vendor must fix it. GSA has some
>>> high-level guidance to develop language like I quoted above at:
>>> https://section508.gov/buy/define-accessibility-criteria.
>>>
>>> --
>>> Ryan E. Benson
>>>
>>>> On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
>>>>
>>>> No.
>>>> VPAT has the word "Voluntary" in it, which to me means "whatever you want."
>>>>
>>>> The government would be better served if they required certification of
>>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any of our
>>>> free or not-so-free tools such as:
>>>>
>>>> Acrobat Pro DC:2018
>>>> Word and PowerPoint built-in checker
>>>> Axes 4
>>>> PAC-3
>>>> NetCentric's Validator
>>>>
>>>> Generally, we find that if the file passes any combo of two of these, then
>>>> it's usually ok, but of course, the best testing is done my knowledgeable
>>>> humans!
>>>>
>>>> --Bevi Chagnon
>>>>
>>>> — — —
>>>> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
>>>> — — —
>>>> PubCom: Technologists for Accessible Design + Publishing
>>>> consulting • training • development • design • sec. 508 services
>>>> Upcoming classes at www.PubCom.com/classes
>>>> — — —
>>>>
>>>>
>>>> -----Original Message-----
>>>> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
>>>> Emily Ogle via WebAIM-Forum
>>>> Sent: Friday, June 1, 2018 4:24 PM
>>>> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
>>>> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
>>>>
>>>> Have any of you ever had to submit VPATs for Word files, PDFs, Excel, etc,
>>>> when providing deliverables to the government?
>>>> >>>> >>>> at http://webaim.org/discussion/archives
>>>> >>>>
>>>> >>>> >>>> >>>> >>>>
>>> >>> >>> >>> >>
>> >> >> >> >
> > > > > > > >

From: Ryan E. Benson
Date: Mon, Jun 04 2018 4:32PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

I am going to answer these questions generally from a HHS perspective. My
agency helped develop this framework. People on the list who are federal
employees, they should talk to their 508 Coordinator, or if the agency has
another resource (I run an agency 508 Help Desk). People also can reach out
to me privately for specifics at my agency.

a) Is it reasonable or plausible that an agency might demand a VPAT for
each deliverable? [RB] yes, this is required, per language in the HHS
Acquisition Regulation. Section 508 coordinators accept the checklists in
place of a VPAT. If the deliverables are identical, such as reports for
each state, and essentially just changing the name of the state, and data,
they may allow one checklist for the group. The pro for this approach is
the contractor/vendor only has to complete the checklist once. The con, if
an error is found, instead of just that one document getting
rejected/returned to be fixed the whole group would be rejected.

b) Is it reasonable to expect that “deliverable” can be construed to
include documents? [RB] Yes, of course. The new standards explicitly cover
electronic documents, see
https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines
for details. but electronic documents are named within the definition of
ICT in E103.4.

c) That while the form of the VPAT must be explicable, the actual nature of
the VPAT itself, on a per-document basis, is up to the agency (vendor,
whatever), providing the document under terms that include a VPAT….yes?
Seems obvious, but always best to ask.
[RB] If you are a vendor wanting to do or currently do business with the US
Government, it is highly recommended to create a VPAT for every [COTS]
product you create, and equally important is keeping it updated. I
recommend updating your VPAT for every major release, at minimum. Having a
VPAT that's two years old, and 3 versions ago, is effectively useless. If
your shop specializes in making accessible PDFs, a document that describes
your process, QA, and what tools you use to assist in that is more helpful
than a VPAT if you are replying to a RFQ, PWS. or another type of
solicitation. The Source Selection Evaluation Team is supposed to take the
respondents knowledge of 508 when making a selection, see
https://www.hhs.gov/grants/contracts/contract-policies-regulations/hhsar/part-339-acquisition-information-technology/index.html#339.203



--
Ryan E. Benson

On Sat, Jun 2, 2018 at 12:02 PM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:

> So, looking for clarity here…
>
> a) Is it reasonable or plausible that an agency might demand a VPAT for
> each deliverable?
>
> b) Is it reasonable to expect that “deliverable” can be construed to
> include documents?
>
> c) That while the form of the VPAT must be explicable, the actual nature
> of the VPAT itself, on a per-document basis, is up to the agency (vendor,
> whatever), providing the document under terms that include a VPAT….yes?
> Seems obvious, but always best to ask.
>
> If all of these are true I have a follow-up question.
>
> Thanks.
>
> Duff.
>
> > On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = > wrote:
> >
> >> VPAT has the word "Voluntary" in it, which to me means "whatever you
> > want."
> >
> > This is incorrect. Yes the V is for voluntary, meaning "here's the
> > documentation without asking for it." If the government asks, you either
> > provide the PAT or risk losing the contract. The company is still able to
> > deny the request, but it's not in your best interest. In terms of
> Emily's
> > question, contract language [often] says provide a VPAT for all
> > deliverables. The checklists I mentioned are an alternative to a VPAT for
> > docs. These are often written in non-legalese to make things easier.
> >
> >> The government would be better served if they required certification of
> > documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
> >
> > A VPAT is literally just that. It is a document that says "We, [company],
> > certify our deliverable meets these standards." As an example, HHS' has
> >
> > d) Respondents to this solicitation must identify any exception to
> Section
> > 508 requirements. If a offeror claims its supplies or services meet
> > applicable Section 508 accessibility standards, and it is later
> determined
> > by the Government, i.e., after award of a contract or order, that
> supplies
> > or services delivered do not conform to the described accessibility
> > standards, remediation of the supplies or services to the level of
> > conformance specified in the contract will be the responsibility of the
> > Contractor at its expense.
> >
> > Source:
> > https://www.hhs.gov/grants/contracts/contract-policies-
> regulations/hhsar/part-352-solicitation-provisions-
> contract-clauses/index.html#352.239-73
> >
> > In English, vendors must document their deliverables meet HHS' standards,
> > the government reserves the right to double check, and if the government
> > finds issues prior to acceptance, the vendor must fix it. GSA has some
> > high-level guidance to develop language like I quoted above at:
> > https://section508.gov/buy/define-accessibility-criteria.
> >
> > --
> > Ryan E. Benson
> >
> > On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
> >
> >> No.
> >> VPAT has the word "Voluntary" in it, which to me means "whatever you
> want."
> >>
> >> The government would be better served if they required certification of
> >> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any of
> our
> >> free or not-so-free tools such as:
> >>
> >> Acrobat Pro DC:2018
> >> Word and PowerPoint built-in checker
> >> Axes 4
> >> PAC-3
> >> NetCentric's Validator
> >>
> >> Generally, we find that if the file passes any combo of two of these,
> then
> >> it's usually ok, but of course, the best testing is done my
> knowledgeable
> >> humans!
> >>
> >> --Bevi Chagnon
> >>
> >> — — —
> >> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
> >> — — —
> >> PubCom: Technologists for Accessible Design + Publishing
> >> consulting • training • development • design • sec. 508 services
> >> Upcoming classes at www.PubCom.com/classes
> >> — — —
> >>
> >>
> >> -----Original Message-----
> >> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
> >> Emily Ogle via WebAIM-Forum
> >> Sent: Friday, June 1, 2018 4:24 PM
> >> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> >> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
> >>
> >> Have any of you ever had to submit VPATs for Word files, PDFs, Excel,
> etc,
> >> when providing deliverables to the government?
> >> > >> > archives
> >> at http://webaim.org/discussion/archives
> >> > >>
> >> > >> > >> > >> > >>
> > > > > > > > >
> > > > >

From: Ryan E. Benson
Date: Mon, Jun 04 2018 4:55PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

I would recommend formally asking to talk to the 508 Coordinator or their
delegate. My agency would expect a checklist for the file types, and our
web checklist for the course - assuming it is an online training, vs
in-person. Our checklist is 3.5 pages long.

> an 84-page document on how to test Word files for accessibility!

I remember when this came out, I honestly laughed. The point of the 84 page
document is to cover every possible nook and cranny. The following may be
helpful: https://section508.gov/test

--
Ryan E. Benson

On Sat, Jun 2, 2018 at 7:46 PM, Emily Ogle via WebAIM-Forum <
= EMAIL ADDRESS REMOVED = > wrote:

> Well, it would seem it is entirely plausible an agency would insist on a
> VPAT for each deliverable, eg, Word, PPT, etc, because that’s happened.
>
> This is unexpected so I’m looking to find out what they’re really
> expecting since we’d have to rethink our strategy by quite a bit. When I
> asked the DHS what the typical expectation was, I was given a link to the
> trusted tester page, in which there was, among several files, an 84-page
> document on how to test Word files for accessibility!
>
> We’re providing training on how to make PPTs etc accessible, but a VPAT
> for each seems like overkill.
>
> > On Jun 2, 2018, at 11:02 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:
> >
> > So, looking for clarity here…
> >
> > a) Is it reasonable or plausible that an agency might demand a VPAT for
> each deliverable?
> >
> > b) Is it reasonable to expect that “deliverable” can be construed to
> include documents?
> >
> > c) That while the form of the VPAT must be explicable, the actual nature
> of the VPAT itself, on a per-document basis, is up to the agency (vendor,
> whatever), providing the document under terms that include a VPAT….yes?
> Seems obvious, but always best to ask.
> >
> > If all of these are true I have a follow-up question.
> >
> > Thanks.
> >
> > Duff.
> >
> >>> On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = >
> wrote:
> >>>
> >>> VPAT has the word "Voluntary" in it, which to me means "whatever you
> >> want."
> >>
> >> This is incorrect. Yes the V is for voluntary, meaning "here's the
> >> documentation without asking for it." If the government asks, you either
> >> provide the PAT or risk losing the contract. The company is still able
> to
> >> deny the request, but it's not in your best interest. In terms of
> Emily's
> >> question, contract language [often] says provide a VPAT for all
> >> deliverables. The checklists I mentioned are an alternative to a VPAT
> for
> >> docs. These are often written in non-legalese to make things easier.
> >>
> >>> The government would be better served if they required certification of
> >> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
> >>
> >> A VPAT is literally just that. It is a document that says "We,
> [company],
> >> certify our deliverable meets these standards." As an example, HHS' has
> >>
> >> d) Respondents to this solicitation must identify any exception to
> Section
> >> 508 requirements. If a offeror claims its supplies or services meet
> >> applicable Section 508 accessibility standards, and it is later
> determined
> >> by the Government, i.e., after award of a contract or order, that
> supplies
> >> or services delivered do not conform to the described accessibility
> >> standards, remediation of the supplies or services to the level of
> >> conformance specified in the contract will be the responsibility of the
> >> Contractor at its expense.
> >>
> >> Source:
> >> https://www.hhs.gov/grants/contracts/contract-policies-
> regulations/hhsar/part-352-solicitation-provisions-
> contract-clauses/index.html#352.239-73
> >>
> >> In English, vendors must document their deliverables meet HHS'
> standards,
> >> the government reserves the right to double check, and if the
> government
> >> finds issues prior to acceptance, the vendor must fix it. GSA has some
> >> high-level guidance to develop language like I quoted above at:
> >> https://section508.gov/buy/define-accessibility-criteria.
> >>
> >> --
> >> Ryan E. Benson
> >>
> >>> On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
> >>>
> >>> No.
> >>> VPAT has the word "Voluntary" in it, which to me means "whatever you
> want."
> >>>
> >>> The government would be better served if they required certification of
> >>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any
> of our
> >>> free or not-so-free tools such as:
> >>>
> >>> Acrobat Pro DC:2018
> >>> Word and PowerPoint built-in checker
> >>> Axes 4
> >>> PAC-3
> >>> NetCentric's Validator
> >>>
> >>> Generally, we find that if the file passes any combo of two of these,
> then
> >>> it's usually ok, but of course, the best testing is done my
> knowledgeable
> >>> humans!
> >>>
> >>> --Bevi Chagnon
> >>>
> >>> — — —
> >>> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
> >>> — — —
> >>> PubCom: Technologists for Accessible Design + Publishing
> >>> consulting • training • development • design • sec. 508 services
> >>> Upcoming classes at www.PubCom.com/classes
> >>> — — —
> >>>
> >>>
> >>> -----Original Message-----
> >>> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf Of
> >>> Emily Ogle via WebAIM-Forum
> >>> Sent: Friday, June 1, 2018 4:24 PM
> >>> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> >>> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
> >>>
> >>> Have any of you ever had to submit VPATs for Word files, PDFs, Excel,
> etc,
> >>> when providing deliverables to the government?
> >>> > >>> > archives
> >>> at http://webaim.org/discussion/archives
> >>> > >>>
> >>> > >>> > >>> > >>> > >>>
> >> > >> > >> > >> > >
> > > > > > > > >
> > > > >

From: Ryan E. Benson
Date: Mon, Jun 04 2018 5:25PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

`> So… my take-away thus far is that agencies can set any expectations for
VPATs (or not) that they want.

No, not really. A VPAT is the legal document that says "yes our deliverable
meets the standards." Many departments (HHS, DHS, SSA, and VA - there may
be a few others) took the legalese and put it into friendlier language, and
in the form of a checklist. Section 508 Coordinators have the authority to
make these decisions and interpretations. What each agency accepts is up to
each agency, but there is a strong effort to make one checklist for each
file type. My recommendation is, if you're providing a service to a federal
agency, and you're not 100% on how they handle 508, or documentation of
it, ask to speak to the agency 508 Coordinator. If your COR can't/won't do
this, please see https://section508.gov/tools/coordinator-listing.

> Do you use the PDF/UA flag as part of your deliverable?

Speaking with knowledge of HHS only. HHS has used PDF/UA as a basis for our
March 2013 release of the PDF checklist. We don't cover every element of
the PDF/UA checklist because there's 130 or so checks in UA's requirements,
as one of 2 primary authors, I knew handing a checklist of 130 to the
various groups that needed to sign off on it, it would never fly. UA is not
explicitly mentioned in the 2013 version because that would blow up for
using a new term. HHS requires our PDF checklist for PDF deliverable. The
checklist is required because there's no 100% accurate test, though I know
some third-party tools come close.



--
Ryan E. Benson

On Mon, Jun 4, 2018 at 12:29 PM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:

> So… my take-away thus far is that agencies can set any expectations for
> VPATs (or not) that they want.
>
> Next question is for those providing services, specifically,
> testing/remediation of PDF documents:
>
> Do you use the PDF/UA flag as part of your deliverable?
>
> Based on what I’m hearing it seems like it would be very handy to have a
> machine-readable indicator that applies to each individual deliverable
> file, as the file would then contain its own certification.
>
> The service-provider could then simply state that when they apply the
> PDF/UA flag it is their indication that the file has passed tests for
> Section 508 conformance.
>
> Of course, it's on the agency adding the flag to ensure that the file
> conforms to WCAG 2.0 Level AA (assuming that’s what applicable in a given
> scenario) as well as PDF/UA, but if you are already doing the latter the
> former should be no big deal.
>
> I’m curious to hear any reactions (positive or negative)...
>
> Duff.
>
>
> > On Jun 4, 2018, at 09:38, Jonathan Avila < = EMAIL ADDRESS REMOVED = >
> wrote:
> >
> >> This is unexpected so I’m looking to find out what they’re really
> expecting since we’d have to rethink our strategy by quite a bit. When I
> asked the DHS what the typical expectation was, I was given a link to the
> trusted tester page, in which there was, among several files, an 84-page
> document on how to test Word files for accessibility!
> >
> > There is an accompanying results spreadsheet for the trusted tester
> process that is to be completed by the Trusted Tester. This spreadsheet
> doesn't appear to be available on the public site but is available on a
> site that is for people who have passed the Trusted Tester Certification
> process. It would document all of the items necessary to understand the
> compliance of the document although not in the same form as a VPAT. As
> others have mentioned many agencies including HHS and VA have their own
> checklists and processes and an agency may ask you to complete their
> documentation in the format/wording that they prefer to have.
> >
> > Jonathan
> >
> > -----Original Message-----
> > From: WebAIM-Forum [mailto: = EMAIL ADDRESS REMOVED = ] On
> Behalf Of Emily Ogle via WebAIM-Forum
> > Sent: Saturday, June 02, 2018 7:47 PM
> > To: WebAIM Discussion List
> > Subject: Re: [WebAIM] VPATs for Word, PPT, Excel, etc.
> >
> > Well, it would seem it is entirely plausible an agency would insist on a
> VPAT for each deliverable, eg, Word, PPT, etc, because that’s happened.
> >
> > This is unexpected so I’m looking to find out what they’re really
> expecting since we’d have to rethink our strategy by quite a bit. When I
> asked the DHS what the typical expectation was, I was given a link to the
> trusted tester page, in which there was, among several files, an 84-page
> document on how to test Word files for accessibility!
> >
> > We’re providing training on how to make PPTs etc accessible, but a VPAT
> for each seems like overkill.
> >
> >> On Jun 2, 2018, at 11:02 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = >
> wrote:
> >>
> >> So, looking for clarity here…
> >>
> >> a) Is it reasonable or plausible that an agency might demand a VPAT for
> each deliverable?
> >>
> >> b) Is it reasonable to expect that “deliverable” can be construed to
> include documents?
> >>
> >> c) That while the form of the VPAT must be explicable, the actual
> nature of the VPAT itself, on a per-document basis, is up to the agency
> (vendor, whatever), providing the document under terms that include a
> VPAT….yes? Seems obvious, but always best to ask.
> >>
> >> If all of these are true I have a follow-up question.
> >>
> >> Thanks.
> >>
> >> Duff.
> >>
> >>>> On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = >
> wrote:
> >>>>
> >>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
> >>> want."
> >>>
> >>> This is incorrect. Yes the V is for voluntary, meaning "here's the
> >>> documentation without asking for it." If the government asks, you
> either
> >>> provide the PAT or risk losing the contract. The company is still able
> to
> >>> deny the request, but it's not in your best interest. In terms of
> Emily's
> >>> question, contract language [often] says provide a VPAT for all
> >>> deliverables. The checklists I mentioned are an alternative to a VPAT
> for
> >>> docs. These are often written in non-legalese to make things easier.
> >>>
> >>>> The government would be better served if they required certification
> of
> >>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
> >>>
> >>> A VPAT is literally just that. It is a document that says "We,
> [company],
> >>> certify our deliverable meets these standards." As an example, HHS' has
> >>>
> >>> d) Respondents to this solicitation must identify any exception to
> Section
> >>> 508 requirements. If a offeror claims its supplies or services meet
> >>> applicable Section 508 accessibility standards, and it is later
> determined
> >>> by the Government, i.e., after award of a contract or order, that
> supplies
> >>> or services delivered do not conform to the described accessibility
> >>> standards, remediation of the supplies or services to the level of
> >>> conformance specified in the contract will be the responsibility of the
> >>> Contractor at its expense.
> >>>
> >>> Source:
> >>> https://www.hhs.gov/grants/contracts/contract-policies-regul
> ations/hhsar/part-352-solicitation-provisions-contract-
> clauses/index.html#352.239-73
> >>>
> >>> In English, vendors must document their deliverables meet HHS'
> standards,
> >>> the government reserves the right to double check, and if the
> government
> >>> finds issues prior to acceptance, the vendor must fix it. GSA has some
> >>> high-level guidance to develop language like I quoted above at:
> >>> https://section508.gov/buy/define-accessibility-criteria.
> >>>
> >>> --
> >>> Ryan E. Benson
> >>>
> >>>> On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
> >>>>
> >>>> No.
> >>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
> want."
> >>>>
> >>>> The government would be better served if they required certification
> of
> >>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any
> of our
> >>>> free or not-so-free tools such as:
> >>>>
> >>>> Acrobat Pro DC:2018
> >>>> Word and PowerPoint built-in checker
> >>>> Axes 4
> >>>> PAC-3
> >>>> NetCentric's Validator
> >>>>
> >>>> Generally, we find that if the file passes any combo of two of these,
> then
> >>>> it's usually ok, but of course, the best testing is done my
> knowledgeable
> >>>> humans!
> >>>>
> >>>> --Bevi Chagnon
> >>>>
> >>>> — — —
> >>>> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
> >>>> — — —
> >>>> PubCom: Technologists for Accessible Design + Publishing
> >>>> consulting • training • development • design • sec. 508 services
> >>>> Upcoming classes at www.PubCom.com/classes
> >>>> — — —
> >>>>
> >>>>
> >>>> -----Original Message-----
> >>>> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf
> Of
> >>>> Emily Ogle via WebAIM-Forum
> >>>> Sent: Friday, June 1, 2018 4:24 PM
> >>>> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> >>>> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
> >>>>
> >>>> Have any of you ever had to submit VPATs for Word files, PDFs, Excel,
> etc,
> >>>> when providing deliverables to the government?
> >>>> > >>>> > archives
> >>>> at http://webaim.org/discussion/archives
> >>>> > >>>>
> >>>> > >>>> > >>>> > >>>> > >>>>
> >>> > >>> > >>> > >>> > >>
> >> > >> > >> > >> > >
> > > > > > > > > > > > > > > > >
> > > > >

From: Emily Ogle
Date: Mon, Jun 04 2018 8:25PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

Thank you, Ryan, for your detailed responses. I guess ultimately the source of our dismay is we had planned on Vpats for our products and created workflows for creating accessible supplementary presentations and word files, but not the VPATs on those presentations themselves. There’s quite a bit of scrambling as we consider the logistics here.

> On Jun 4, 2018, at 6:25 PM, Ryan E. Benson < = EMAIL ADDRESS REMOVED = > wrote:
>
> `> So… my take-away thus far is that agencies can set any expectations for
> VPATs (or not) that they want.
>
> No, not really. A VPAT is the legal document that says "yes our deliverable
> meets the standards." Many departments (HHS, DHS, SSA, and VA - there may
> be a few others) took the legalese and put it into friendlier language, and
> in the form of a checklist. Section 508 Coordinators have the authority to
> make these decisions and interpretations. What each agency accepts is up to
> each agency, but there is a strong effort to make one checklist for each
> file type. My recommendation is, if you're providing a service to a federal
> agency, and you're not 100% on how they handle 508, or documentation of
> it, ask to speak to the agency 508 Coordinator. If your COR can't/won't do
> this, please see https://section508.gov/tools/coordinator-listing.
>
>> Do you use the PDF/UA flag as part of your deliverable?
>
> Speaking with knowledge of HHS only. HHS has used PDF/UA as a basis for our
> March 2013 release of the PDF checklist. We don't cover every element of
> the PDF/UA checklist because there's 130 or so checks in UA's requirements,
> as one of 2 primary authors, I knew handing a checklist of 130 to the
> various groups that needed to sign off on it, it would never fly. UA is not
> explicitly mentioned in the 2013 version because that would blow up for
> using a new term. HHS requires our PDF checklist for PDF deliverable. The
> checklist is required because there's no 100% accurate test, though I know
> some third-party tools come close.
>
>
>
> --
> Ryan E. Benson
>
>> On Mon, Jun 4, 2018 at 12:29 PM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:
>>
>> So… my take-away thus far is that agencies can set any expectations for
>> VPATs (or not) that they want.
>>
>> Next question is for those providing services, specifically,
>> testing/remediation of PDF documents:
>>
>> Do you use the PDF/UA flag as part of your deliverable?
>>
>> Based on what I’m hearing it seems like it would be very handy to have a
>> machine-readable indicator that applies to each individual deliverable
>> file, as the file would then contain its own certification.
>>
>> The service-provider could then simply state that when they apply the
>> PDF/UA flag it is their indication that the file has passed tests for
>> Section 508 conformance.
>>
>> Of course, it's on the agency adding the flag to ensure that the file
>> conforms to WCAG 2.0 Level AA (assuming that’s what applicable in a given
>> scenario) as well as PDF/UA, but if you are already doing the latter the
>> former should be no big deal.
>>
>> I’m curious to hear any reactions (positive or negative)...
>>
>> Duff.
>>
>>
>>> On Jun 4, 2018, at 09:38, Jonathan Avila < = EMAIL ADDRESS REMOVED = >
>> wrote:
>>>
>>>> This is unexpected so I’m looking to find out what they’re really
>> expecting since we’d have to rethink our strategy by quite a bit. When I
>> asked the DHS what the typical expectation was, I was given a link to the
>> trusted tester page, in which there was, among several files, an 84-page
>> document on how to test Word files for accessibility!
>>>
>>> There is an accompanying results spreadsheet for the trusted tester
>> process that is to be completed by the Trusted Tester. This spreadsheet
>> doesn't appear to be available on the public site but is available on a
>> site that is for people who have passed the Trusted Tester Certification
>> process. It would document all of the items necessary to understand the
>> compliance of the document although not in the same form as a VPAT. As
>> others have mentioned many agencies including HHS and VA have their own
>> checklists and processes and an agency may ask you to complete their
>> documentation in the format/wording that they prefer to have.
>>>
>>> Jonathan
>>>
>>> -----Original Message-----
>>> From: WebAIM-Forum [mailto: = EMAIL ADDRESS REMOVED = ] On
>> Behalf Of Emily Ogle via WebAIM-Forum
>>> Sent: Saturday, June 02, 2018 7:47 PM
>>> To: WebAIM Discussion List
>>> Subject: Re: [WebAIM] VPATs for Word, PPT, Excel, etc.
>>>
>>> Well, it would seem it is entirely plausible an agency would insist on a
>> VPAT for each deliverable, eg, Word, PPT, etc, because that’s happened.
>>>
>>> This is unexpected so I’m looking to find out what they’re really
>> expecting since we’d have to rethink our strategy by quite a bit. When I
>> asked the DHS what the typical expectation was, I was given a link to the
>> trusted tester page, in which there was, among several files, an 84-page
>> document on how to test Word files for accessibility!
>>>
>>> We’re providing training on how to make PPTs etc accessible, but a VPAT
>> for each seems like overkill.
>>>
>>>> On Jun 2, 2018, at 11:02 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = >
>> wrote:
>>>>
>>>> So, looking for clarity here…
>>>>
>>>> a) Is it reasonable or plausible that an agency might demand a VPAT for
>> each deliverable?
>>>>
>>>> b) Is it reasonable to expect that “deliverable” can be construed to
>> include documents?
>>>>
>>>> c) That while the form of the VPAT must be explicable, the actual
>> nature of the VPAT itself, on a per-document basis, is up to the agency
>> (vendor, whatever), providing the document under terms that include a
>> VPAT….yes? Seems obvious, but always best to ask.
>>>>
>>>> If all of these are true I have a follow-up question.
>>>>
>>>> Thanks.
>>>>
>>>> Duff.
>>>>
>>>>>> On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = >
>> wrote:
>>>>>>
>>>>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
>>>>> want."
>>>>>
>>>>> This is incorrect. Yes the V is for voluntary, meaning "here's the
>>>>> documentation without asking for it." If the government asks, you
>> either
>>>>> provide the PAT or risk losing the contract. The company is still able
>> to
>>>>> deny the request, but it's not in your best interest. In terms of
>> Emily's
>>>>> question, contract language [often] says provide a VPAT for all
>>>>> deliverables. The checklists I mentioned are an alternative to a VPAT
>> for
>>>>> docs. These are often written in non-legalese to make things easier.
>>>>>
>>>>>> The government would be better served if they required certification
>> of
>>>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
>>>>>
>>>>> A VPAT is literally just that. It is a document that says "We,
>> [company],
>>>>> certify our deliverable meets these standards." As an example, HHS' has
>>>>>
>>>>> d) Respondents to this solicitation must identify any exception to
>> Section
>>>>> 508 requirements. If a offeror claims its supplies or services meet
>>>>> applicable Section 508 accessibility standards, and it is later
>> determined
>>>>> by the Government, i.e., after award of a contract or order, that
>> supplies
>>>>> or services delivered do not conform to the described accessibility
>>>>> standards, remediation of the supplies or services to the level of
>>>>> conformance specified in the contract will be the responsibility of the
>>>>> Contractor at its expense.
>>>>>
>>>>> Source:
>>>>> https://www.hhs.gov/grants/contracts/contract-policies-regul
>> ations/hhsar/part-352-solicitation-provisions-contract-
>> clauses/index.html#352.239-73
>>>>>
>>>>> In English, vendors must document their deliverables meet HHS'
>> standards,
>>>>> the government reserves the right to double check, and if the
>> government
>>>>> finds issues prior to acceptance, the vendor must fix it. GSA has some
>>>>> high-level guidance to develop language like I quoted above at:
>>>>> https://section508.gov/buy/define-accessibility-criteria.
>>>>>
>>>>> --
>>>>> Ryan E. Benson
>>>>>
>>>>>> On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
>>>>>>
>>>>>> No.
>>>>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
>> want."
>>>>>>
>>>>>> The government would be better served if they required certification
>> of
>>>>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any
>> of our
>>>>>> free or not-so-free tools such as:
>>>>>>
>>>>>> Acrobat Pro DC:2018
>>>>>> Word and PowerPoint built-in checker
>>>>>> Axes 4
>>>>>> PAC-3
>>>>>> NetCentric's Validator
>>>>>>
>>>>>> Generally, we find that if the file passes any combo of two of these,
>> then
>>>>>> it's usually ok, but of course, the best testing is done my
>> knowledgeable
>>>>>> humans!
>>>>>>
>>>>>> --Bevi Chagnon
>>>>>>
>>>>>> — — —
>>>>>> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
>>>>>> — — —
>>>>>> PubCom: Technologists for Accessible Design + Publishing
>>>>>> consulting • training • development • design • sec. 508 services
>>>>>> Upcoming classes at www.PubCom.com/classes
>>>>>> — — —
>>>>>>
>>>>>>
>>>>>> -----Original Message-----
>>>>>> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf
>> Of
>>>>>> Emily Ogle via WebAIM-Forum
>>>>>> Sent: Friday, June 1, 2018 4:24 PM
>>>>>> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
>>>>>> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
>>>>>>
>>>>>> Have any of you ever had to submit VPATs for Word files, PDFs, Excel,
>> etc,
>>>>>> when providing deliverables to the government?
>>>>>> >>>>>> >> archives
>>>>>> at http://webaim.org/discussion/archives
>>>>>> >>>>>>
>>>>>> >>>>>> >>>>>> >>>>>> >>>>>>
>>>>> >>>>> >>>>> >>>>> >>>>
>>>> >>>> >>>> >>>> >>>
>>> >>> >>> >>> >>> >>> >>> >>> >>
>> >> >> >> >>
> > > >

From: Ryan E. Benson
Date: Mon, Jun 04 2018 8:33PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

I recommend reaching out to the 508 Coordinator via your COR. You can of
course contact the 508 Coordinator yourself, but when a contractor does
this - my office's first question is 'who is your COR?' (Some agencies
call them COTR, or similar, but the FTE you report to.)

--
Ryan E. Benson

On Mon, Jun 4, 2018 at 10:25 PM, Emily Ogle via WebAIM-Forum <
= EMAIL ADDRESS REMOVED = > wrote:

> Thank you, Ryan, for your detailed responses. I guess ultimately the
> source of our dismay is we had planned on Vpats for our products and
> created workflows for creating accessible supplementary presentations and
> word files, but not the VPATs on those presentations themselves. There’s
> quite a bit of scrambling as we consider the logistics here.
>
> > On Jun 4, 2018, at 6:25 PM, Ryan E. Benson < = EMAIL ADDRESS REMOVED = >
> wrote:
> >
> > `> So… my take-away thus far is that agencies can set any expectations
> for
> > VPATs (or not) that they want.
> >
> > No, not really. A VPAT is the legal document that says "yes our
> deliverable
> > meets the standards." Many departments (HHS, DHS, SSA, and VA - there may
> > be a few others) took the legalese and put it into friendlier language,
> and
> > in the form of a checklist. Section 508 Coordinators have the authority
> to
> > make these decisions and interpretations. What each agency accepts is up
> to
> > each agency, but there is a strong effort to make one checklist for each
> > file type. My recommendation is, if you're providing a service to a
> federal
> > agency, and you're not 100% on how they handle 508, or documentation of
> > it, ask to speak to the agency 508 Coordinator. If your COR can't/won't
> do
> > this, please see https://section508.gov/tools/coordinator-listing.
> >
> >> Do you use the PDF/UA flag as part of your deliverable?
> >
> > Speaking with knowledge of HHS only. HHS has used PDF/UA as a basis for
> our
> > March 2013 release of the PDF checklist. We don't cover every element of
> > the PDF/UA checklist because there's 130 or so checks in UA's
> requirements,
> > as one of 2 primary authors, I knew handing a checklist of 130 to the
> > various groups that needed to sign off on it, it would never fly. UA is
> not
> > explicitly mentioned in the 2013 version because that would blow up for
> > using a new term. HHS requires our PDF checklist for PDF deliverable. The
> > checklist is required because there's no 100% accurate test, though I
> know
> > some third-party tools come close.
> >
> >
> >
> > --
> > Ryan E. Benson
> >
> >> On Mon, Jun 4, 2018 at 12:29 PM, Duff Johnson < = EMAIL ADDRESS REMOVED = >
> wrote:
> >>
> >> So… my take-away thus far is that agencies can set any expectations for
> >> VPATs (or not) that they want.
> >>
> >> Next question is for those providing services, specifically,
> >> testing/remediation of PDF documents:
> >>
> >> Do you use the PDF/UA flag as part of your deliverable?
> >>
> >> Based on what I’m hearing it seems like it would be very handy to have a
> >> machine-readable indicator that applies to each individual deliverable
> >> file, as the file would then contain its own certification.
> >>
> >> The service-provider could then simply state that when they apply the
> >> PDF/UA flag it is their indication that the file has passed tests for
> >> Section 508 conformance.
> >>
> >> Of course, it's on the agency adding the flag to ensure that the file
> >> conforms to WCAG 2.0 Level AA (assuming that’s what applicable in a
> given
> >> scenario) as well as PDF/UA, but if you are already doing the latter the
> >> former should be no big deal.
> >>
> >> I’m curious to hear any reactions (positive or negative)...
> >>
> >> Duff.
> >>
> >>
> >>> On Jun 4, 2018, at 09:38, Jonathan Avila < = EMAIL ADDRESS REMOVED = >
> >> wrote:
> >>>
> >>>> This is unexpected so I’m looking to find out what they’re really
> >> expecting since we’d have to rethink our strategy by quite a bit. When I
> >> asked the DHS what the typical expectation was, I was given a link to
> the
> >> trusted tester page, in which there was, among several files, an 84-page
> >> document on how to test Word files for accessibility!
> >>>
> >>> There is an accompanying results spreadsheet for the trusted tester
> >> process that is to be completed by the Trusted Tester. This
> spreadsheet
> >> doesn't appear to be available on the public site but is available on a
> >> site that is for people who have passed the Trusted Tester Certification
> >> process. It would document all of the items necessary to understand the
> >> compliance of the document although not in the same form as a VPAT. As
> >> others have mentioned many agencies including HHS and VA have their own
> >> checklists and processes and an agency may ask you to complete their
> >> documentation in the format/wording that they prefer to have.
> >>>
> >>> Jonathan
> >>>
> >>> -----Original Message-----
> >>> From: WebAIM-Forum [mailto: = EMAIL ADDRESS REMOVED = ] On
> >> Behalf Of Emily Ogle via WebAIM-Forum
> >>> Sent: Saturday, June 02, 2018 7:47 PM
> >>> To: WebAIM Discussion List
> >>> Subject: Re: [WebAIM] VPATs for Word, PPT, Excel, etc.
> >>>
> >>> Well, it would seem it is entirely plausible an agency would insist on
> a
> >> VPAT for each deliverable, eg, Word, PPT, etc, because that’s happened.
> >>>
> >>> This is unexpected so I’m looking to find out what they’re really
> >> expecting since we’d have to rethink our strategy by quite a bit. When I
> >> asked the DHS what the typical expectation was, I was given a link to
> the
> >> trusted tester page, in which there was, among several files, an 84-page
> >> document on how to test Word files for accessibility!
> >>>
> >>> We’re providing training on how to make PPTs etc accessible, but a VPAT
> >> for each seems like overkill.
> >>>
> >>>> On Jun 2, 2018, at 11:02 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = >
> >> wrote:
> >>>>
> >>>> So, looking for clarity here…
> >>>>
> >>>> a) Is it reasonable or plausible that an agency might demand a VPAT
> for
> >> each deliverable?
> >>>>
> >>>> b) Is it reasonable to expect that “deliverable” can be construed to
> >> include documents?
> >>>>
> >>>> c) That while the form of the VPAT must be explicable, the actual
> >> nature of the VPAT itself, on a per-document basis, is up to the agency
> >> (vendor, whatever), providing the document under terms that include a
> >> VPAT….yes? Seems obvious, but always best to ask.
> >>>>
> >>>> If all of these are true I have a follow-up question.
> >>>>
> >>>> Thanks.
> >>>>
> >>>> Duff.
> >>>>
> >>>>>> On Jun 1, 2018, at 22:49, Ryan E. Benson < = EMAIL ADDRESS REMOVED = >
> >> wrote:
> >>>>>>
> >>>>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
> >>>>> want."
> >>>>>
> >>>>> This is incorrect. Yes the V is for voluntary, meaning "here's the
> >>>>> documentation without asking for it." If the government asks, you
> >> either
> >>>>> provide the PAT or risk losing the contract. The company is still
> able
> >> to
> >>>>> deny the request, but it's not in your best interest. In terms of
> >> Emily's
> >>>>> question, contract language [often] says provide a VPAT for all
> >>>>> deliverables. The checklists I mentioned are an alternative to a VPAT
> >> for
> >>>>> docs. These are often written in non-legalese to make things easier.
> >>>>>
> >>>>>> The government would be better served if they required certification
> >> of
> >>>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1).
> >>>>>
> >>>>> A VPAT is literally just that. It is a document that says "We,
> >> [company],
> >>>>> certify our deliverable meets these standards." As an example, HHS'
> has
> >>>>>
> >>>>> d) Respondents to this solicitation must identify any exception to
> >> Section
> >>>>> 508 requirements. If a offeror claims its supplies or services meet
> >>>>> applicable Section 508 accessibility standards, and it is later
> >> determined
> >>>>> by the Government, i.e., after award of a contract or order, that
> >> supplies
> >>>>> or services delivered do not conform to the described accessibility
> >>>>> standards, remediation of the supplies or services to the level of
> >>>>> conformance specified in the contract will be the responsibility of
> the
> >>>>> Contractor at its expense.
> >>>>>
> >>>>> Source:
> >>>>> https://www.hhs.gov/grants/contracts/contract-policies-regul
> >> ations/hhsar/part-352-solicitation-provisions-contract-
> >> clauses/index.html#352.239-73
> >>>>>
> >>>>> In English, vendors must document their deliverables meet HHS'
> >> standards,
> >>>>> the government reserves the right to double check, and if the
> >> government
> >>>>> finds issues prior to acceptance, the vendor must fix it. GSA has
> some
> >>>>> high-level guidance to develop language like I quoted above at:
> >>>>> https://section508.gov/buy/define-accessibility-criteria.
> >>>>>
> >>>>> --
> >>>>> Ryan E. Benson
> >>>>>
> >>>>>> On Fri, Jun 1, 2018 at 4:47 PM, < = EMAIL ADDRESS REMOVED = > wrote:
> >>>>>>
> >>>>>> No.
> >>>>>> VPAT has the word "Voluntary" in it, which to me means "whatever you
> >> want."
> >>>>>>
> >>>>>> The government would be better served if they required certification
> >> of
> >>>>>> documents files for Sec. 508 compliant (WCAG 2.0, PDF/UA-1). Use any
> >> of our
> >>>>>> free or not-so-free tools such as:
> >>>>>>
> >>>>>> Acrobat Pro DC:2018
> >>>>>> Word and PowerPoint built-in checker
> >>>>>> Axes 4
> >>>>>> PAC-3
> >>>>>> NetCentric's Validator
> >>>>>>
> >>>>>> Generally, we find that if the file passes any combo of two of
> these,
> >> then
> >>>>>> it's usually ok, but of course, the best testing is done my
> >> knowledgeable
> >>>>>> humans!
> >>>>>>
> >>>>>> --Bevi Chagnon
> >>>>>>
> >>>>>> — — —
> >>>>>> Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
> >>>>>> — — —
> >>>>>> PubCom: Technologists for Accessible Design + Publishing
> >>>>>> consulting • training • development • design • sec. 508 services
> >>>>>> Upcoming classes at www.PubCom.com/classes
> >>>>>> — — —
> >>>>>>
> >>>>>>
> >>>>>> -----Original Message-----
> >>>>>> From: WebAIM-Forum < = EMAIL ADDRESS REMOVED = > On Behalf
> >> Of
> >>>>>> Emily Ogle via WebAIM-Forum
> >>>>>> Sent: Friday, June 1, 2018 4:24 PM
> >>>>>> To: WebAIM Discussion List < = EMAIL ADDRESS REMOVED = >
> >>>>>> Subject: [WebAIM] VPATs for Word, PPT, Excel, etc
> >>>>>>
> >>>>>> Have any of you ever had to submit VPATs for Word files, PDFs,
> Excel,
> >> etc,
> >>>>>> when providing deliverables to the government?
> >>>>>> > >>>>>> > >> archives
> >>>>>> at http://webaim.org/discussion/archives
> >>>>>> > >>>>>>
> >>>>>> > >>>>>> > >>>>>> > >>>>>> > >>>>>>
> >>>>> > >>>>> > >>>>> > >>>>> > >>>>
> >>>> > >>>> > >>>> > >>>> > >>>
> >>> > >>> > >>> > >>> > >>> > >>> > >>> > >>> > >>
> >> > >> > >> > >> > >>
> > > > > > > > >
> > > > >

From: Duff Johnson
Date: Wed, Jun 06 2018 12:56PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

Thanks for the information, Ryan,

> What each agency accepts is up to
> each agency, but there is a strong effort to make one checklist for each
> file type.

Ok, I thought so. This is helpful… I will have a idea put-together to bounce off you soon. :-)

>> Do you use the PDF/UA flag as part of your deliverable?
>
> Speaking with knowledge of HHS only. HHS has used PDF/UA as a basis for our
> March 2013 release of the PDF checklist.

OK, excellent.

> We don't cover every element of
> the PDF/UA checklist because there's 130 or so checks in UA's requirements,

Technically true, but since 87 of those checks don’t require a human (except to review failures), and the rest are the inevitable “human judgement” questions such as logical reading order and semantic appropriateness, testing for PDF/UA conformance doesn’t have to be too fraught.

> as one of 2 primary authors, I knew handing a checklist of 130 to the
> various groups that needed to sign off on it, it would never fly. UA is not
> explicitly mentioned in the 2013 version because that would blow up for
> using a new term. HHS requires our PDF checklist for PDF deliverable. The
> checklist is required because there's no 100% accurate test, though I know
> some third-party tools come close.

OK, so…

- PDF/UA helped inform development of your own checklist
- But you don’t use the fact of the claim of PDF/UA conformance (which is intended for use only when all software and human-checks have been verified for that file) as part of your model? Is that so?

What I’m getting at is: If someone has claimed PDF/UA, and if the claim is trustworthy… what are the other checks that apply? I’m thinking… perhaps the specific color-contrast checks defined in WCAG 2.0?

Could the checklist for PDF be simpler if it was composed of:

- PDF/UA conformance (verified by vendor and spot-tested (or whatever) by the procuring agency
- Additional specifications (i.e., the gap between whatever PDF/UA represents and the standard you want to meet)

Is the problem…
- PDF/UA is TOO restrictive? (perhaps, because it requires sensible heading-levels)
- PDF/UA is too hard to achieve with current tools?
- Other?

I am NOT judging / doubting / complaining! I just want to understand how you thought about this.

Thanks,

Duff.

From: Ryan E. Benson
Date: Wed, Jun 06 2018 6:30PM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

> Technically true, but since 87 of those checks don’t require a human
(except to review failures), and the rest are the inevitable “human
judgement” questions such as logical reading order and semantic
appropriateness, testing for PDF/UA conformance doesn’t have to be too
fraught.

How accurate is that though? Unless there have been big changes in the last
year, most of those 87 are trust, but verify.

> - But you don’t use the fact of the claim of PDF/UA conformance (which is
intended for use only when all software and human-checks have been verified
for that file) as part of your model? Is that so?

The checklist was written in 2013, did not want to require external tools.
To get conformance at that time, you either needed a good understanding of
UA, or a third-party tool and decent knowledge. That is largely true still
today. For HHS, a PDF is considered accessible if it passes our checklist.
It involves passing the built-in checker.

> What I’m getting at is: If someone has claimed PDF/UA, and if the claim
is trustworthy… what are the other checks that apply? I’m thinking… perhaps
the specific color-contrast checks defined in WCAG 2.0?

In theory, then the PDF should pass HHS checklist, with the exception of
maybe the HHS policy guidance at the top of the checklist, for example "All
Document properties should be filled out Title, Author, (an HHS OpDiv,
StaffDiv, or Program Office---not an individual’s names) Subject, and
Keywords." Re contrast: remember the WCAG 2.0 is the minimum, so there was
a business decision to axe the large text or 14 pt and bold part to hold
stuff to a higher level.

> PDF/UA is TOO restrictive? (perhaps, because it requires sensible
heading-levels)
As an SME, no of course not! As somebody who barely know how to use Word,
yes. I would love to plop down the Matterhorn Protocol, but the base level
of knowledge is not at that level. I had to thread the needle between
getting good stuff and not putting off large swaths of people. For example,
lists. In 2013, to get the best support for AT, at that time, you needed l,
li, lbody, and lbl. To get those 4 tags, I remember having to trade a few
of the other things that I wanted to add. This was 5.5 years ago, so what
exactly that was, is beyond me.

>- PDF/UA is too hard to achieve with current tools?
Yes. Resources is included in that too.

--
Ryan E. Benson

On Wed, Jun 6, 2018 at 2:56 PM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:

> Thanks for the information, Ryan,
>
> > What each agency accepts is up to
> > each agency, but there is a strong effort to make one checklist for each
> > file type.
>
> Ok, I thought so. This is helpful… I will have a idea put-together to
> bounce off you soon. :-)
>
> >> Do you use the PDF/UA flag as part of your deliverable?
> >
> > Speaking with knowledge of HHS only. HHS has used PDF/UA as a basis for
> our
> > March 2013 release of the PDF checklist.
>
> OK, excellent.
>
> > We don't cover every element of
> > the PDF/UA checklist because there's 130 or so checks in UA's
> requirements,
>
> Technically true, but since 87 of those checks don’t require a human
> (except to review failures), and the rest are the inevitable “human
> judgement” questions such as logical reading order and semantic
> appropriateness, testing for PDF/UA conformance doesn’t have to be too
> fraught.
>
> > as one of 2 primary authors, I knew handing a checklist of 130 to the
> > various groups that needed to sign off on it, it would never fly. UA is
> not
> > explicitly mentioned in the 2013 version because that would blow up for
> > using a new term. HHS requires our PDF checklist for PDF deliverable. The
> > checklist is required because there's no 100% accurate test, though I
> know
> > some third-party tools come close.
>
> OK, so…
>
> - PDF/UA helped inform development of your own checklist
> - But you don’t use the fact of the claim of PDF/UA conformance (which is
> intended for use only when all software and human-checks have been verified
> for that file) as part of your model? Is that so?
>
> What I’m getting at is: If someone has claimed PDF/UA, and if the claim is
> trustworthy… what are the other checks that apply? I’m thinking… perhaps
> the specific color-contrast checks defined in WCAG 2.0?
>
> Could the checklist for PDF be simpler if it was composed of:
>
> - PDF/UA conformance (verified by vendor and spot-tested (or whatever) by
> the procuring agency
> - Additional specifications (i.e., the gap between whatever PDF/UA
> represents and the standard you want to meet)
>
> Is the problem…
> - PDF/UA is TOO restrictive? (perhaps, because it requires sensible
> heading-levels)
> - PDF/UA is too hard to achieve with current tools?
> - Other?
>
> I am NOT judging / doubting / complaining! I just want to understand how
> you thought about this.
>
> Thanks,
>
> Duff.
> > > > >

From: Duff Johnson
Date: Fri, Jun 08 2018 9:49AM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | Next message →

> On Jun 6, 2018, at 20:30, Ryan E. Benson < = EMAIL ADDRESS REMOVED = > wrote:
>
>> Technically true, but since 87 of those checks don’t require a human
> (except to review failures)

That’s very true… but review of failures is inevitable. I guess the problem here is that too many PDF files are still of poor quality (from an accessibility point of view) out of the egg.

> , and the rest are the inevitable “human
> judgement” questions such as logical reading order and semantic
> appropriateness, testing for PDF/UA conformance doesn’t have to be too
> fraught.
>
> How accurate is that though? Unless there have been big changes in the last
> year, most of those 87 are trust, but verify.

Well, the 87 machine tests have to do with factors that aren’t something humans would normally verify. Either fonts are embedded, or they are not. Either there’s Title metadata, or there is not. Either a language is set, or it is not, and so on. Now.. is the language set correctly? That’s a different check.. and that is indeed either a “trust the provider” or a “human check required” - but I’m not sure how that’s avoided at all, irrespective of technology.
>
>> - But you don’t use the fact of the claim of PDF/UA conformance (which is
> intended for use only when all software and human-checks have been verified
> for that file) as part of your model? Is that so?
>
> The checklist was written in 2013, did not want to require external tools.
> To get conformance at that time, you either needed a good understanding of
> UA, or a third-party tool and decent knowledge. That is largely true still
> today. For HHS, a PDF is considered accessible if it passes our checklist.
> It involves passing the built-in checker.

OK, so the checker (I assume you mean Adobe’s) is part of your evaluation. If your checker used PDF/UA, you would be able to check that much more about the file in an automated fashion.

>> What I’m getting at is: If someone has claimed PDF/UA, and if the claim
> is trustworthy… what are the other checks that apply? I’m thinking… perhaps
> the specific color-contrast checks defined in WCAG 2.0?
>
> In theory, then the PDF should pass HHS checklist, with the exception of
> maybe the HHS policy guidance at the top of the checklist, for example "All
> Document properties should be filled out Title, Author, (an HHS OpDiv,
> StaffDiv, or Program Office---not an individual’s names) Subject, and
> Keywords.”

Right; that’s a policy thing, and PDF/UA can’t take responsibility for it; of course.

> Re contrast: remember the WCAG 2.0 is the minimum, so there was
> a business decision to axe the large text or 14 pt and bold part to hold
> stuff to a higher level.

Also a policy thing.

OK, so if….

1) The file claimed to be PDF/UA, and
2) You had a PDF/UA validator that did all the machine checks AND provided a good user interface and experience for human checks, and
3) You could add your policies (WCAG-specific, or otherwise) into that validator, then…

- You’d have a dramatically simplified model!

I’ve written a short article that (I hope) explains this.

https://www.pdfa.org/using-pdfua-in-accessibility-checklists/

>> PDF/UA is TOO restrictive? (perhaps, because it requires sensible
> heading-levels)
> As an SME, no of course not! As somebody who barely know how to use Word,
> yes. I would love to plop down the Matterhorn Protocol, but the base level
> of knowledge is not at that level.

…which is another way of saying that the tools don’t yet do enough of the work. The poor user should never have to see the Matterhorn Protocol unless they want DETAIL about a given failure or suspicious case. Otherwise, they should simply be concerned with: (a) is the logical reading order correct, (b) are the semantics (Figure, Heading, Paragraph, List, etc) correct, and whether or not they are obeying rules with respect to color, contrast, etc.

> I had to thread the needle between
> getting good stuff and not putting off large swaths of people. For example,
> lists. In 2013, to get the best support for AT, at that time, you needed l,
> li, lbody, and lbl.

Still true; all four structure elements are required for proper encoding of lists in PDF.

> To get those 4 tags, I remember having to trade a few
> of the other things that I wanted to add. This was 5.5 years ago, so what
> exactly that was, is beyond me.

Interesting! So, this is all driven by the tools. If the tools were smarter about applying the four list structure element types without human help, then you would not have to trade to get this right.

>> - PDF/UA is too hard to achieve with current tools?
> Yes. Resources is included in that too.

Really good to know; thanks!

Duff.

From: Ryan E. Benson
Date: Sat, Jun 09 2018 9:38AM
Subject: Re: VPATs for Word, PPT, Excel, etc.
← Previous message | No next message

> I guess the problem here is that too many PDF files are still of poor
quality (from an accessibility point of view) out of the egg

eggactly (sorry). But yes, that is the other side of the coin. I mentioned
I couldn't plop down the full PDF/UA checklist, but I am hoping some day we
can get closer to that. The flip side is look at HTML, most people would
say automatic tools only can hit 45% of issues if we are being generous.

> Now.. is the language [and metadata] set correctly? That’s a different
check..

Usually PDF Creators grab the author's details for the author metadata, so
for me it is Benson, Ryan E (HHS/Agency/Center/Division). To protect
employees, we require the author metadata be Center/Division or Name of
Program, so that's a test that is not useful. You point out the issue with
language, I would argue that one is pointless because a human still has to
check. Yes you can pop up a dialog to show those details, but I would argue
telling people how to look at the properties directly.

> If your checker used PDF/UA, you would be able to check that much more
about the file in an automated fashion.

In the blurb above this line, you talked about how yes you can test the
language, but a human still need to verify that it is set correctly. l
would say it isn't worth counting as a test because the results aren't
reliable at the end of the day.

> Otherwise, they should simply be concerned with: [snip]

Yes. That was my undocumented baseline, and had to parse them out into
non-technical English.

> If the tools were smarter about applying the four list structure element
types without human help, then you would not have to trade to get this
right.

YES! Also the cost of the tool is a factor.

--
Ryan E. Benson

On Fri, Jun 8, 2018 at 11:49 AM, Duff Johnson < = EMAIL ADDRESS REMOVED = > wrote:

>
> > On Jun 6, 2018, at 20:30, Ryan E. Benson < = EMAIL ADDRESS REMOVED = > wrote:
> >
> >> Technically true, but since 87 of those checks don’t require a human
> > (except to review failures)
>
> That’s very true… but review of failures is inevitable. I guess the
> problem here is that too many PDF files are still of poor quality (from an
> accessibility point of view) out of the egg.
>
> > , and the rest are the inevitable “human
> > judgement” questions such as logical reading order and semantic
> > appropriateness, testing for PDF/UA conformance doesn’t have to be too
> > fraught.
> >
> > How accurate is that though? Unless there have been big changes in the
> last
> > year, most of those 87 are trust, but verify.
>
> Well, the 87 machine tests have to do with factors that aren’t something
> humans would normally verify. Either fonts are embedded, or they are not.
> Either there’s Title metadata, or there is not. Either a language is set,
> or it is not, and so on. Now.. is the language set correctly? That’s a
> different check.. and that is indeed either a “trust the provider” or a
> “human check required” - but I’m not sure how that’s avoided at all,
> irrespective of technology.
> >
> >> - But you don’t use the fact of the claim of PDF/UA conformance (which
> is
> > intended for use only when all software and human-checks have been
> verified
> > for that file) as part of your model? Is that so?
> >
> > The checklist was written in 2013, did not want to require external
> tools.
> > To get conformance at that time, you either needed a good understanding
> of
> > UA, or a third-party tool and decent knowledge. That is largely true
> still
> > today. For HHS, a PDF is considered accessible if it passes our
> checklist.
> > It involves passing the built-in checker.
>
> OK, so the checker (I assume you mean Adobe’s) is part of your evaluation.
> If your checker used PDF/UA, you would be able to check that much more
> about the file in an automated fashion.
>
> >> What I’m getting at is: If someone has claimed PDF/UA, and if the claim
> > is trustworthy… what are the other checks that apply? I’m thinking…
> perhaps
> > the specific color-contrast checks defined in WCAG 2.0?
> >
> > In theory, then the PDF should pass HHS checklist, with the exception of
> > maybe the HHS policy guidance at the top of the checklist, for example
> "All
> > Document properties should be filled out Title, Author, (an HHS OpDiv,
> > StaffDiv, or Program Office---not an individual’s names) Subject, and
> > Keywords.”
>
> Right; that’s a policy thing, and PDF/UA can’t take responsibility for it;
> of course.
>
> > Re contrast: remember the WCAG 2.0 is the minimum, so there was
> > a business decision to axe the large text or 14 pt and bold part to hold
> > stuff to a higher level.
>
> Also a policy thing.
>
> OK, so if….
>
> 1) The file claimed to be PDF/UA, and
> 2) You had a PDF/UA validator that did all the machine checks AND provided
> a good user interface and experience for human checks, and
> 3) You could add your policies (WCAG-specific, or otherwise) into that
> validator, then…
>
> - You’d have a dramatically simplified model!
>
> I’ve written a short article that (I hope) explains this.
>
> https://www.pdfa.org/using-pdfua-in-accessibility-checklists/
>
> >> PDF/UA is TOO restrictive? (perhaps, because it requires sensible
> > heading-levels)
> > As an SME, no of course not! As somebody who barely know how to use Word,
> > yes. I would love to plop down the Matterhorn Protocol, but the base
> level
> > of knowledge is not at that level.
>
> …which is another way of saying that the tools don’t yet do enough of the
> work. The poor user should never have to see the Matterhorn Protocol unless
> they want DETAIL about a given failure or suspicious case. Otherwise, they
> should simply be concerned with: (a) is the logical reading order correct,
> (b) are the semantics (Figure, Heading, Paragraph, List, etc) correct, and
> whether or not they are obeying rules with respect to color, contrast, etc.
>
> > I had to thread the needle between
> > getting good stuff and not putting off large swaths of people. For
> example,
> > lists. In 2013, to get the best support for AT, at that time, you needed
> l,
> > li, lbody, and lbl.
>
> Still true; all four structure elements are required for proper encoding
> of lists in PDF.
>
> > To get those 4 tags, I remember having to trade a few
> > of the other things that I wanted to add. This was 5.5 years ago, so what
> > exactly that was, is beyond me.
>
> Interesting! So, this is all driven by the tools. If the tools were
> smarter about applying the four list structure element types without human
> help, then you would not have to trade to get this right.
>
> >> - PDF/UA is too hard to achieve with current tools?
> > Yes. Resources is included in that too.
>
> Really good to know; thanks!
>
> Duff.
> > > > >