The New Section 508: Modeling Usability, Interoperability, and Harmonization
The text alternative to a PowerPoint presentation delivered by Mike Paciello, co-chair, Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC), at the October 22, 2008, meeting of Boston-IA.
- Introduction to TEITAC
- §508 of the Rehabilitation Act
- applies to federal agencies: all electronic and information technology (E&IT)
- employees and members of the public
- §255 of the 1996 Communications Act
- applies to entire telecom market: equipment manufacturers and service providers in telecom and interconnected VoIP
- TEITAC did not address service provider issues
- Frequent requests for clarification and technical assistance on 508
- what products are covered?
- just procurement, or use also?
- Global market = international harmonization; many other standards activities underway
- Technology convergence
- products migrating across the 6 categories used in Section 508
- widespread adoption of wireless and VoIP
- Federal agencies
- ICT and AT industries and their trade associations
- Standards organizations
- Consumer advocates
- Researchers and developers
- National and international (EU, Japan, Canada, Australia) policy experts and consultants
- Broad public participation
- 8 Subcommittees
- General Interface, Web/Software, Telecommunications, Audio-Video, Self-Contained, Hardware, Subpart A, Documentation
41 TEITAC Members
- Adobe Systems, Inc.
- American Association of People with Disabilities
- American Council of the Blind
- American Foundation for the Blind
- AOL LLC
- Apple, Inc.
- Association of Assistive Technology Act Programs
- Assistive Technology Industry Association
- Avaya, Inc.
- Canon USA, Inc.
- Communication Service for the Deaf
- CTIA - The Wireless Association
- Dell, Inc.
- Easter Seals
- European Commission
- Hearing Loss Association of America
- Human Rights and Equal Opportunity Commission (Australia)
- Inclusive Technologies
- Industry Canada
- Information Technology Association of America
- Information Technology Industry Council
- Japanese Standards Association
- Microsoft Corporation
- National Association of State Chief Information Officers
- National Center on Disability and Access to Education
- National Federation of the Blind
- National Network of Disability and Business Technical Assistance Centers
- Panasonic Corporation of North America
- Paralyzed Veterans of America
- SRA International, Inc.
- Sun Microsystems, Inc.
- Telecommunications Industry Association
- The Paciello Group (TPG), LLC
- Trace Research and Development Center
- Usability Professionals' Association
- U.S. Department of Homeland Security
- U.S. Social Security Administration
- WGBH National Center for Accessible Media
- World Wide Web Consortium – Web Accessibility Initiative
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TEITAC Results (1 of 4)
- More provisions, but more testable and largely harmonized with other standards
- Technical Provisions and Functional Performance Criteria (FPCs)
- Structure and strength of recommendation
- recommended provisions
- provisions without consensus
- "best practices"
- notes, for Access Board or implementers
- Includes cognitive disabilities
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TEITAC Results (2 of 4)
- "Product characteristics" rather than "product categories"
- "Real-time Voice Conversation Functionality", not "Telephone systems"
- Beyond procurement: specific implementation and use provisions
- agencies must provide access to relay services, including video
- agencies must configure accessibility features
- agency-created content ("official agency communications") is covered
TEITAC Results (3 of 4)
- Specific to 255/Telecom
- access to relay services
- software in telecom products
- volume control & amplification
- real-time text
- interactive voice response (IVR) provisions
TEITAC Results (4 of 4)
- Software, Web, other content, and interface behavior now largely converged into "User Interface and Electronic Content"
- Web is now an application platform
- actual user requirements virtually the same as desktop software
- current standard only addresses Web content
- everyone creates content
- Access Board will take Report and develop a proposed rule, NPRM
- Comment period
- Final Rule
- Federal Acquisition Regulations (FAR)
- balance accessibility with other drivers
- FCC action?
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- Information tools and "Communities of Practice"
- "provision inflation" and complexity
- consistent procurement practices
- testing results (or at least protocols, metrics)
- workarounds and user interface settings
- VPAT, BuyAccessible, Trace Filter
- Research & development
- better metrics and tests for hearing and vision
- emerging technologies
- cognitive disabilities
- assistance with AT-ICT interoperability
- EU: Mandate 376
- accessibility standards inventory (includes Section 508)
- development of European Standards (harmonization)
- conformity assessment models and protocols
- many require accessibility, based on some or all of 508
- some cover education, local government, state funding recipients
- States lack GSA-type TA, 508 coordinators
- complexity is burdensome, results in narrowing the scope or relaxing the provision
Slide 13 (last slide):
- TEITAC Report addresses (but does not resolve) all of the issues
- unresolved: AT-ICT interoperability, when to apply FPCs
- Rulemaking will be … lively
- Implementation issues involve many federal, state, international actors
Slide 14: Handout
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