How Do I Get Thru This Mine Field?

In 1998, Congress amended the Rehabilitation Act of 1973 to require Federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities.

The law applies to all Federal agencies when they develop, procure, maintain, or use electronic and information technology.

Individuals with disabilities may file an administrative complaint with the GSA Office of Civil Rights and said item will be reviewed and brought into compliance with the provisions of Section 508.

So, where are the land mines?

A Little Background

Mine Field Philosophy1. Detection – know the types and location of land

mines3 key subsections of Section 508

2. Removal – preventing a miss-step• Resources• Tools• Techniques

Land Mine DetectionKnow the 3 key elements of the Section 508 Standards

• 1194.1 Purpose

individuals with disabilities have access to and use of information and data

unless an undue burden would be imposed on the agency

Land Mine Detection…unless an undue burden would be imposed on the agency

Undue burden is defined as:…an action that would result in significant difficulty or expense considering all agency resources available to the agency or component (36 CFR 1194.4 and FAR 39.202)

• You can’t claim undue burden because its inconvenient for you to find a compliant product

• You can’t claim undue burden because you’ll have marginal additional cost in bringing a system into compliance

• You can’t claim undue burden because you screwed up and chose the wrong product/ service

• You can’t claim undue burden because a compliant product is more expensive than a non-compliant one

Land Mine RemovalUndue burden is an expense or effort that it would pose an actual threat to the component or program’s ability to do business.

This means it depends on the size of the agency or program within the agency.

It also means that a compliant website or web-based application should never qualify for an undue burden exemption.

Even under an undue burden the information and data must be provided through an alternate means.

Land Mine RemovalClaiming an undue burden, the Agency: (FAR 39.204(e)(2)(i))

• must identify and document the reason• clearly disclose the specific provisions which cannot

be met• show how expensive it would be to meet the provisions• Show the market research activities which lead to the

conclusion• include other supporting documentation

Even if you have the proper AGENCY documentation, an individuals with disabilities may file an administrative complaint and GSA Office of Civil Rights will determine if the item will be brought into compliance.

I have a Section 508 Waiver!

Land Mine RemovalRESOURCES:

• http://www.section508.gov

• http://www.gsa.gov/portal/category/26811

• http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards/guide-to-the-section-508-standards

Land Mine Detection• 1194.22 Web-based intranet and internet information and

applicationsa) A text equivalent for every non-text element shall be

providedb) Equivalent alternatives for any multimedia

presentation shall be synchronized with the presentation

c) Web pages shall be designed so that all information conveyed with color is also available without color

d) Documents shall be organized so they are readable without requiring an associated style sheet

e) Redundant text links shall be provided for each active region of a server-side image map

f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape

Land Mine Detectiong) Row and column headers shall be identified for data

tablesh) Markup shall be used to associate data cells and

header cells for data tables that have two or more logical levels of row or column headers

i) Frames shall be titled with text that facilitates frame identification and navigation

j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz

k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way

Land Mine Detectionl) When pages utilize scripting languages to display

content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology

m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with §1194.21(a) through (l)

n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues

o) A method shall be provided that permits users to skip repetitive navigation links

p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required

Land Mine RemovalResources

• http://www.section508.gov/how• http://www.gsa.gov/portal/content/103565

Tools:• Content Authoring – Lectora, Captivate, Flash, Storyline• Checklist - webaim.org/standards/508/508checklist.pdf

Techniques:• http://www.jimthatcher.com/webcourse1.htm

Land Mine Detection• 1194.24 Video and multimedia products

c) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned.

d) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall be audio described.

Land Mine Removalc) All training and informational video and multimedia

productions which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned.

The term "multimedia productions" refers to productions that present information in more than one sensory mode, e.g., both audibly and visually.

Open captioned – Text is displayed all the time and cannot be turned off

Closed captioned – Text can be turned on or off

Remember, text needs to be synchronized with the video or media.

Land Mine Removald) All training and informational video and multimedia

productions which support the agency's mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall be audio described.

If there is visual information—such as action, expressions, images, or graphics—in the video that is necessary to understand the production's content, that information must be described in an audio file, which also must be synchronized with the video.

Land Mine Removal

LIVE VIDEO/Multimedia must have captioning and audio descriptions. (U.S. Access Board)

Land Mine RemovalResources

• http://www.howto.gov/web-content/accessibility/508-compliant-and-accessible-multimedia

• www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-section-508-standards/guide-to-the-section-508-standards/video-and-multimedia-products-1194-24gov/portal/content/103565

Techniques:• joeclark.org/access/description/ad-principles.html

FUTURESerious Gaming – http://igda-gasig.org/about-game-accessibility/additional-information/section-508-article/

Social Media – http://www.howto.gov/social-media/using-social-media-in-government/improving-accessibility

United States Access Board is updating the Section 508 guidelines and will cover more documents, more technology and more people. The Access Board proposes directly referencing the Web Content Accessibility Guidelines (WCAG 2.0) level A and AA success criteria, not only for web content but also for web applications, software, and documents in general.

Questions?Milan Hatch, Instructional Systems SpecialistInstructional Technology DepartmentNational Corrections AcademyFederal Bureau of Prisons303.338.6554mhatch@bop.gov