Making IT Accessible: Section 508 Overview

Betsy SirkSection 508 CoordinatorNASA Goddard Space Flight CenterAugust 17, 2011

Agenda

• What is Section 508?• Scope• Current Technical Standards• Proposed New Standards/Refresh • NASA Section 508 Accomplishments• Next Steps• Resources

What is Section 508?

• Section 508 of the Rehabilitation Act of 1973 as amended by Congress in 1998 requires that Federal employees with disabilities have access to and use of information and data, comparable to that for Federal employees without disabilities, unless it is an undue burden to do so.

• Section 508 also requires that disabled members of the public who are seeking information or services from a Federal agency, have access to and use of information and data comparable to that for members of the public without disabilities.

• Section 508 applies to Federal agencies, including the U.S. Postal Service.

• Contractors providing services or products to Federal agencies must provide Section 508 compliant deliverables.

Scope

• Electronic and information technology (EIT) products procured, developed, maintained, or used by a Federal agency, including products that store, process, transmit, convert, duplicate, or receive electronic information. (Examples: copiers, computers, fax machines, software, hardware, websites, telephones)

• Limited number of exceptions apply: • EIT incidental to a contract (not part of the government deliverable)• EIT deemed to be for national security• EIT used in areas frequented only by service personnel for maintenance,

repair or occasional monitoring (Example: telephone closets)

• Undue burden, defined as significant difficulty or expense, is rarely invoked. Requires approval of Center legal counsel.

• You are not required to fundamentally alter your requirements if a compliant solution is not available.

Current Technical Standards

• Section 508 Technical Standards published in the Federal Register in December 2000. The Federal Acquisition Regulation was amended to include the Section 508 Standards in April 2001

• Enforcement of the Section 508 standards began June 2001

• Standards and Technical Specifications organized by types of “products”:– 1194.21 Software Applications and Operating Systems– 1194.22 Web-based Information and Applications– 1194.23 Telecommunications Products– 1194.24 Video and Multimedia Products– 1194.25 Self Contained, Closed Products– 1194.26 Desktop and Portable Computers.

Proposed New Standards: Section 508 Refresh

• United States Access Board issued an Advance Notice of Proposed Rulemaking (ANPRM) and draft text in March 2010 to update:– Standards for electronic and information technology (Section 508), – Telecommunications Act Accessibility Guidelines (Section 255)– Americans with Disabilities Act Accessibility Guidelines

• Public comment period ended June 2010 • What is different in the proposed standards?

– Electronic and Information Technology (EIT) replaced with Information and Communications Technology (ICT)

– Organization has changed – feature based– Advisory Notes next to provisions– Reflects current technology– Definition of content – what is covered– Web Content Accessibility Guidelines (WCAG) 2.0 Harmonization

Proposed New Standards:Organization

Chapter 1- 508; Chapter 1 – 255 (Telecommunications Act)

Chapter 2 Functional Performance Criteria

Chapter 3 Common Functionality

Chapter 4 Platforms, Applications and Interactive Content

Chapter 5 Electronic Documents

Chapter 6 Synchronized Media Content and Players

Chapter 7 Hardware Aspects of ICT

Chapter 8 Audio Output from Hardware

Chapter 9 Conversation Functionality and Controls

Chapter 10 ICT Support Documentation and Services

Chapter 1• “Official” communication from agency or representative of

the agency to Federal employees and contains information necessary to perform job, or to members of the public necessary to conduct official business with the agency

• Examples of communications to federal workforce: – Announcements about working conditions or policies

– Announcements of upcoming agency events, training opportunities

• Examples of communications to the public:– Technical assistance about agency regulations

– Content posted on the agency website

– Information about benefits or programs administered or provided by the agency

Chapters 2 & 3• Chapter 2- Functional Performance Criteria

– 202.2 Without Vision – 202.3 With Limited Vision – 202.4 Without Perception of Color – 202.5 Without Hearing – 202.6 With Limited Hearing – 202.7 Without Speech – 202.8 With Limited Manipulation – 202.9 With Limited Reach and Strength – 202.10 Without Physical Contact – 202.11 Minimize Photosensitive Seizure Triggers 

• Chapter 3- Common Functionality to all ICT– 301 General– 302 Closed Functionality– 303 Biometrics– 304 Preservation of Information Provided for Accessibility– 305 Color– 306 Flashing– 307 Operable Parts

Chapters 4 & 5

• WCAG 2.0 Harmonization• International standard for accessible web pages:

http://w3.org/tr/wcag• Chapter 4 (“Web”)

– Platforms, Applications, and Interactive Content• Chapter 5 (“Documents”)

– Electronic documents – mostly static, read-only, non-interactive content

– Examples: Word files, PDFs, PowerPoint presentations, Excel spreadsheets, simple web pages (without Flash)

Chapters 6 & 7• Chapter 6: Synchronized Media Content and Players

– 601 General– 602 Video or Audio Content with Interactive Elements– 603 Captions and Transcripts for Audio Content– 604 Video Description and Transcripts for Video Content– 605 Caption Processing Technology– 606 Video Description Processing Technology– 607 User Controls for Captions and Video Description– 608 Audio Track and Volume Control

• Chapter 7: Hardware Aspects of ICT– 701 General– 702 Reach Ranges for Installed or Free-Standing ICT– 703 Standard Connections– 704 Text, Images of Text, and Symbols for Product Use

Chapters 8-10• Chapter 8: Audio Output from Hardware

– 801 General– 802 Interactive ICT Within Reach– 803 ICT Typically Held to the Ear– 804 ICT Not Typically Held to the Ear

• Chapter 9: Conversation Functionality and Controls – 901 General– 902 Real-Time Text Functionality– 903 Voice Mail, Messaging, Auto-Attendant, Conferencing, and Interactive Voice Response

– 904 Information about Call Status and Functions– 905 Video Communication Support– 906 Audio Clarity for Interconnected VoIP– 907 Alternate Alerting for VoIP Telephone Systems

• Chapter 10: ICT Support Documentation and ICT Support Services– 1001 General– 1002 ICT Support Documentation– 1003 ICT Support Services

Refresh Process:What is Next?

United States Access Board will:• Finish analyzing comments• Develop proposed rule and issue notice • Develop regulatory assessment • Submit to Office of Management and Budget • Publish Notice of Proposed Rule Making in the Federal

Register (followed by public comment period)• Issue final rule (Refresh implemented)• For information and updates:

– http://www.access-board.gov/sec508/refresh/draft-rule.htm– 508@access-board.gov– http://www.access-board.gov

NASA Section 508 Accomplishments

• NASA Procedural Requirement (NPR 2800.2, Electronic and Information Technology Accessibility), outlining NASA roles and responsibilities for Section 508 compliance, implemented January 2011

Requirements• Procurement of EIT• Technical and Functional Criteria for Compliance with Section 508 of EIT• Special Topics (Multimedia, Lab Equipment, etc.)• Applicability and Exceptions

Roles and Responsibilities• Chief Information Officer• Agency Section 508 Coordinator• Center Chief Information Officer• Center 508 Coordinators• Office of Procurement• Office of Diversity and Equal Opportunity• Office of General Counsel• Program/Project Managers• Requirements Originator/Developer

NASA Section 508 Accomplishments

(continued)

• NASA Section 508 Website enhanced– Accessibility Guides for Excel, Word, and PowerPoint documents

– Best practices

– http://www.nasa.gov/accessibility/nasaonly/nasaOnly_policyResources.html

• Deployed a procurement tool to assist with Section 508 compliance– Accessibility Compliance for EIT (ACE) Tool v1.0

– Checklist for assessing need for compliance

– Helps one determine which Section 508 Technical Standards may apply

– http://www.nasa.gov/accessibility/ace

• Section 508 provisions considered in the development of agency procurement initiatives, including I3P

• Responded to Department of Justice Survey on the status of Section 508 implementation April 2011

Next Steps

• Hold Agency Section 508 Coordinators Working Group Meeting August 2011

• Identify, develop, and provide Section 508 training opportunities

• Develop Section 508 Implementation Plans as needed to address compliance gaps

• Collaborate with Office of Diversity and Equal Opportunity to promote accessibility.

Resources

• Current listing of NASA Section 508 Coordinators by Center: http://www.nasa.gov/accessibility/section508/sec508_coordinators.html

• Other helpful sites for technical assistance:

www.section508.gov (maintained by GSA)

www.access-board.gov

Many thanks to Tim Creagan of the United States Access Board for the content of the Refresh Slides

• For NASA Employees (civil servant and contractor): email Section 508 questions to section508help@nasa.gov

• Questions about this presentation:

email: betsy.sirk@nasa.gov

phone: 301-286-0150

THANK YOU VERY MUCH FOR ATTENDING!