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Thread: When is 508 required? :)
Number of posts in this thread: 10 (In chronological order)
From: Andrea Miralia
Date: Thu, Jun 21 2018 6:59AM
Subject: When is 508 required? :)
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Hi all,
I'm wondering about a potential request that may be coming my way. A government client wants to make sure a few thousand Excel documents are 508 compliant, but these documents will be exchanged privately between the companies and the government. They won't be publicly available, and there aren't any employees accessing these files who need them to be 508 compliant. One of my colleagues said they need to be compliant because "you never know" who might be working on the documents in the future. But what is the law, really? I am looking, of course, but I figured I'd ask all of you, too.
From: BF Devs
Date: Thu, Jun 21 2018 7:06AM
Subject: Re: When is 508 required? :)
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Most interpretations of the law I've seen is that if a government agency that is liable under 508 is involved, internal and external communications are covered, unless they meet specific exemptions, regardless of if someone currently is known to need accommodation or not. Partly this is because people may have disabilities that are temporary or not reported as such (such as someone just needing a new eye exam), or employee turnover meaning while someone now may not need accommodation, someone in the next year or so might. Etc.
Hope that helps.
-Katriel Paige
Sent from my iPhone
> On Jun 21, 2018, at 8:59 AM, Andrea Miralia < = EMAIL ADDRESS REMOVED = > wrote:
>
>
>
> Hi all,
>
> I'm wondering about a potential request that may be coming my way. A government client wants to make sure a few thousand Excel documents are 508 compliant, but these documents will be exchanged privately between the companies and the government. They won't be publicly available, and there aren't any employees accessing these files who need them to be 508 compliant. One of my colleagues said they need to be compliant because "you never know" who might be working on the documents in the future. But what is the law, really? I am looking, of course, but I figured I'd ask all of you, too.
>
>
>
>
> > > >
From: Ryan E. Benson
Date: Thu, Jun 21 2018 10:10AM
Subject: Re: When is 508 required? :)
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What Katriel said is correct. You could see if it will only ever be used be
a small (under 20) group where nobody has a disability if you don't want to
make it accessible, but I don't recommend that. I'll note that you cannot
poll the users if they have a disability.
[Andrea] But what is the law, really?
Here you go:
https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines#E205-content
--
Ryan E. Benson
On Thu, Jun 21, 2018 at 9:06 AM, BF Devs < = EMAIL ADDRESS REMOVED = > wrote:
> Most interpretations of the law I've seen is that if a government agency
> that is liable under 508 is involved, internal and external communications
> are covered, unless they meet specific exemptions, regardless of if someone
> currently is known to need accommodation or not. Partly this is because
> people may have disabilities that are temporary or not reported as such
> (such as someone just needing a new eye exam), or employee turnover meaning
> while someone now may not need accommodation, someone in the next year or
> so might. Etc.
>
> Hope that helps.
>
> -Katriel Paige
>
>
>
> Sent from my iPhone
>
> > On Jun 21, 2018, at 8:59 AM, Andrea Miralia <
> = EMAIL ADDRESS REMOVED = > wrote:
> >
> >
> >
> > Hi all,
> >
> > I'm wondering about a potential request that may be coming my way. A
> government client wants to make sure a few thousand Excel documents are 508
> compliant, but these documents will be exchanged privately between the
> companies and the government. They won't be publicly available, and there
> aren't any employees accessing these files who need them to be 508
> compliant. One of my colleagues said they need to be compliant because "you
> never know" who might be working on the documents in the future. But what
> is the law, really? I am looking, of course, but I figured I'd ask all of
> you, too.
> >
> >
> >
> >
> > > > > > > > > > > > >
From: chagnon
Date: Thu, Jun 21 2018 11:10AM
Subject: Re: When is 508 required? :)
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Another good place to go to read the intent of the law is the US Federal Register, where all federal laws and regulations are published. The 508 Refresh is Document Number 2017-00395.
In it, the Access Board gives us the reasoning behind their decisions which can help you decide how best to meet the regulations or what is covered, what isn't.
https://www.federalregister.gov/documents/2017/01/18/2017-00395/information-and-communication-technology-ict-standards-and-guidelines
â â â
Bevi Chagnon, founder/CEO | = EMAIL ADDRESS REMOVED =
â â â
PubCom: Technologists for Accessible Design + Publishing
consulting ' training ' development ' design ' sec. 508 services
Upcoming classes at www.PubCom.com/classes
â â â
From: mhysnm1964
Date: Fri, Jun 22 2018 12:31AM
Subject: Re: When is 508 required? :)
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This is interesting. As the section 508 is about procurement. Thus Excel
needs to be accessible. But does spreadsheets from a third-party need to be?
If you are selling them a service maybe? This is a legal question in deed.
From: Andrea Miralia
Date: Fri, Jun 22 2018 10:06AM
Subject: Re: When is 508 required? :)
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One thing I am wondering is why, in the past, other contractors have remediated the Excel spreadsheets both before *and after* the individual companies have filled them out. This seems unnecessary to me, as again, the spreadsheets are not being published anywhere; they're just being used to manage information like company name and address and membership numbers.
Anyone know why both the blank spreadsheets and the filled-in spreadsheets would have to be compliant? Seems excessive.
From: Jonathan Avila
Date: Fri, Jun 22 2018 10:33AM
Subject: Re: When is 508 required? :)
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While Section 508 is generally enforced through procurement it covers the use, maintenance, and development of ICT as well. Employees and members of the public have a civil right to access ICT in a comparable manner available to people without disabilities. There are 9 types of non-public documents that are covered by Section 508 to ensure that information needed by citizens of this country and employees with disabilities can have the same access as others.
Jonathan
Jonathan Avila
Chief Accessibility Officer
Level Access
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From: Andrea Miralia
Date: Fri, Jun 22 2018 10:53AM
Subject: Re: When is 508 required? :)
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What is "ICT?"
Anyway, my question was more... If the Excel spreadsheet is compliant before data is entered, it shouldn't really change after the data is entered. The participants won't be adding formulas or merging cells (and in fact, we might lock the documents so that they can't), so ... it seems unnecessary to re-remediate them and make sure they're still compliant after the data has been entered.
From: chagnon
Date: Fri, Jun 22 2018 11:16AM
Subject: Re: When is 508 required? :)
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ICT = Information Communications Technology.
Broad term to define any digital file format that communicates information.
So broad that it can define just about anything created or used on a digital
device / computer, regardless of the file format, method of distribution,
device used to access or read it, or how it is stored.
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
From: Jonathan Avila
Date: Fri, Jun 22 2018 4:50PM
Subject: Re: When is 508 required? :)
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> Anyway, my question was more... If the Excel spreadsheet is compliant before data is entered, it shouldn't really change
It is possible in Excel to add color formatting, symbols, etc. to content within cells. So in theory someone adding content to the cell could create an accessibility issue. But given that much will be locked down then it is less likely that someone would break accessibility in other ways such as by adding textboxes, images, etc.. If nothing was added in an inaccessible manner there would be no need for remediation. So the answer is it depends on what the user actually does/can do.
If you do plan to lock the cells and prevent selection of locked cells then you will likely need to use input messages to communicate the cell labels to users of screen readers because the users won't be able to read the cells outside the unlocked region.
Jonathan