Sec. 508 for Managers Technical Reference

1 Sec. 508 for Managers Technical Reference Sec. 508 for Managers Technical Reference April 2017 Presented by: Bevi Chagnon Founding Partner bevi@pubcom.com

2 Sec. 508 for Managers Technical Reference Contents Sec. 508 for Managers Technical Reference... 1 1. Sec. 508: What it does and why... 3 2. Sec. 508 Refresh: What it covers... 4 What must be accessible... 4 Which agencies are affected... 5 Effective and enforcement dates... 5 Legacy Documents Safe Harbor clause also referenced in Apx. A, Chapter 2 E202.2 Legacy ICT... 6 US Federal Agencies that regulate and enforce Sec. 508 throughout the federal sector... 7 3. The Accessibility Standards... 8 Standards vs. Guidelines... 8 WCAG 2.0... 8 PDF/UA 1.0... 8 4. How accessibility works... 9 The 4 Core Principles of Accessibility POUR... 9 All stakeholders will do their part:... 10 5. How to make Sec. 508 work for your agency... 11 Agency-wide policy should:... 11 6. Examples of workflows that work.... 13 7. Contracting for outsourcing Sec. 508 services... 15 Specify the digital deliverables for ICT... 15 8. Sample contract language for accessibility... 17

3 Sec. 508 for Managers Technical Reference 1. Sec. 508: What it does and why Note: References to the Sec. 508 standards of January 2017 are shown in blue italics preceded by [Ref:]. Anit-discrimination legislation, requires equal access by those with disabilities to federal information in all digital formats. [Ref: Apx. C, Chapter 3 302] 1. Without vision 2. With limited vision 3. Without perception of color 4. Without hearing 5. With limited hearing 6. Without speech 7. With limited manipulation 8. With limited reach and strength 9. With limited language, cognitive, and learning abilities Guarantees access to the general public. [Ref: Apx. A, Chapter 2 203.a] Guarantees access to federal employees. [Ref: Apx. A, Chapter 2 203.b] Adopts international accessibility standards for the US federal government, rather than writing our own standards as before (Harmonization) [Ref: Executive Order 13609: Promoting International Regulatory Cooperation] Makes our federal digital information computer readable and technology independent: Works for all AT Works across most cross-media publishing technologies Improves SEO Harmonizes with other accessibile ITC worldwide Robust More likely to work with future technologies

4 Sec. 508 for Managers Technical Reference 2. Sec. 508 Refresh: What it covers What must be accessible 1. The new 2017 rule: https://www.access-board.gov/guidelines-andstandards/communications-and-it/about-the-ict-refresh/overview-of-the-finalrule 2. Apply to ICT developed, procured, maintained, or used by federal agencies. Examples include computers, telecommunications equipment, multifunction office machines such as copiers that also function as printers, software, websites, information kiosks and transaction machines, and electronic documents. ICT created by contractors as part of their work on behalf of the agency, or submitted as digital deliverables, are considered to be covered by this clause. ICT created by grant recipients as part of their work under the grant, or submitted as digital deliverables, are considered by most agencies to be covered by this clause. However, this is not explicitly defined in the Sec. 508 rule. 3. Specifies that all types of public-facing content, as well as nine categories of non-public-facing content that communicate agency official business, have to be accessible, with content encompassing all forms of electronic information and data. Public-facing ICT [Ref: Apx. A, Chapter 2 E205.2] 1. Websites 2. Documents, Word, PDFs, email 3. Blog posts and social media 4. Software 5. Telecomm equipment (Sec. 255) 6. Kiosks Non-public-facing ICT (internal agency communication) [Ref: Apx. A, Chapter 2 E205.3] 1. Emergency notifications 2. Initial or final decisions adjudicating administrative claims or proceedings 3. Internal or external program or policy announcements 4. Notices of benefits, program eligibility, employment opportunities or personnel actions 5. Formal acknowledgements or receipts

5 Sec. 508 for Managers Technical Reference 6. Questionnaires or surveys 7. Templates or forms 8. Educational or training materials 9. Web-based intranets Support documentation and services [Ref: Apx. C, Chapter 6] 1. Product documentation for hardware and software [Ref: 602.1] 2. Electronic documentation [Ref: 602.3] 3. Support services, help desks, call centers, training services, and automated technical support [Ref: 603] Which agencies are affected Any agency or department of the United States as defined in 44 U.S.C. 3502, and the United States Postal Service. [Ref: Apx. A, Chapter 1 E103.4] Compliance with these standards is mandatory for Federal agencies subject to Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. 794d). [Ref: Apx. A, Chapter 1 E101.1 ] Exemptions [Ref: Apx. A, Chapter 2 E202] Note: #202.4 (Federal Contracts) states that ICT acquired by a contractor is exempt. This refers to the contractor s personal ICT created during the operation of its business and is not part of their contract work for the agency. Corporate and private sector ICT is exempt from Sec. 508. However, the work the contractor performs on behalf of an agency or provides as digital deliverables is required to be Sec. 508 compliant. Effective and enforcement dates https://www.access-board.gov/guidelines-and-standards/communications-andit/about-the-ict-refresh/final-rule Section 508 mandates that, within six months, both the Federal Acquisition Regulatory Council (FAR Council) and Federal agencies incorporate these revised standards into their respective acquisition regulations and procurement policies and directives. Thus, with respect to procurement-related matters, the Access Board s 508 Standards are not self-enforcing; rather, these standards take legal effect when adopted by the FAR Council. Federal agencies will have one year from publication of this final rule to comply with the Revised 508 Standards. This extended period for compliance is responsive

6 Sec. 508 for Managers Technical Reference to some agencies concerns about the time it will take them to make ICT compliant with the Revised 508 Standards. Compliance date = January 21, 2018. All new content from this date forward must be fully compliant. Legacy content that is compliant per the old standard before this date is grandfathered (Safe Harbor Clause below). However, if this legacy content is changed or edited after this date, it must be brought up to the new accessibility standards. Legacy content that is not compliant by this date must now be made compliant. Legacy Documents Safe Harbor clause [Ref: also referenced in Apx. A, Chapter 2 E202.2 Legacy ICT] In addition, the Revised 508 Standards include a safe harbor provision for existing (i.e., legacy) ICT. Under this safe harbor, unaltered, existing ICT (including content) that complies with the existing 508 Standards need not be modified or upgraded to conform to the Revised 508 Standards. Existing ICT that conforms to the old 508 standards will be compliant after January 21, 2018, unless it is altered in any way. When existing ICT is edited or updated, it will no longer be grandfathered and will have to meet the new 508 standards. Existing/legacy ICT that isn t compliant by January 21, 2018 will be required to be made compliant to the new 508 standards.

7 Sec. 508 for Managers Technical Reference US Federal Agencies that regulate and enforce Sec. 508 throughout the federal sector The US Access Board maintains the regulations for accessibility in these areas www.access-board.gov 1. ICT and IT Sec. 508 and Sec. 255 2. Buildings and sites ADA and ABA 3. Recreation facilities ADA and ABA 4. Streets, sidewalks, and rights of way ADA and ABA 5. Transportation ADA and ABA 6. Health care Patient Protection and Affodable Care Act DOJ enforces the regulations and handles complaints and lawsuits, except for transportation which is enforced by the Department of Transportation. GSA informs the federal sector about accessibility requirements for ICT and IT.

8 Sec. 508 for Managers Technical Reference 3. The Accessibility Standards Standards vs. Guidelines Standards are success criteria or checkpoints Examine the end result and evaluate it against the standards The file either meets the required standard or it fails Guidelines are suggested methods for meeting the success criteria or checkpoints Are suggested ways, techniques, or methods to meet the requirements Allow flexibility in how the file is created Different methods and techniques for different types of content WCAG 2.0 Developed for accessible websites Also for other HTML-based technologies, such as EPUB Somewhat applies to PDFs and other document file formats Is the main standard referenced in Sec. 508 Developed by W3C https://www.w3.org/wai Adopted and managed by the ISO ISO/IEC 40500:2012 https://www.iso.org/standard/58625.html Incorporated by reference into Sec. 508 [Ref: Apx. C, Chapter 7 702.10 and Apx. A, Chapter 2 205.4] PDF/UA 1.0 Developed for accessible PDF documents Makes a more accessible and user-friendly PDF than WCAG, takes advantage of features in the PDF format Also can be applied to Word, PowerPoint, and other document file formats Is a secondary reference in Sec. 508 Developed by the PDF Association https://www.pdfa.org/workinggroup/pdfua-competence-center/ Adopted and managed by the ISO ISO 3200-1:2008 https://www.iso.org/standard/51502.html Incorporated by reference into Sec. 508 [Ref: Apx. C, Chapter 7 702.3 and Apx. C, Chapter 5 504.2.2 PDF Export.]

9 Sec. 508 for Managers Technical Reference 4. How accessibility works The 4 Core Principles of Accessibility POUR 1. Perceivable 2. Operable 3. Understandable 4. Robust These overall guiding priniciples apply to all forms of ICT, regardless of which standard you re using, WCAG or PDF/UA. They allow ICT to be accessible, readable, and usable to people with all kinds of disabilities. Without the standards, most people with disabilities would not be able to fully use the Internet, common office software, fill out forms, or perform any other computer-related tasks so necessary in today s world. Regardless of the ICT, the key requirements to make it accessible are: Content is tagged with a known set of <tags> that identify different parts of the content, such as <H1> for heading level 1, <table> for tables, and other items. The content s reading order is controlled so that computer assisted technologies will voice or present it in a logical order to the user. All non-text content, such as graphics, have Alt-text added to them that describes the visual information in the graphic. Alt-text generally is not visiable to those who are sighted, but it is voiced or presented to some assistive technologies such as screen readers. Navigation methods are built into the ITC. For websites, this is often accomplished by navigation menus. For documents, a table of contents can provide navigation throughout the document. Multi-media is captioned for those who are hearing- or sight-impaired. Closed captioning is one type of captioning for this purpose. Audio/video ICT has user controls for volume, speed, backup/forward, and on/off. ICT conforms to the standards so that it will be usable for the longterm. This is just a short summary of the major accessibility points. WCAG 2.0 has over 200 success criteria or checkpoints for accessibility. All WCAG checkpoints apply to websites and HTML content, but only about 20 of them have relevance for PDFs and other documents. Sec. 508 notes that the PDF/UA standard is an accepted alternative standard for documents (and this is also PubCom s recommended standard for them).

10 Sec. 508 for Managers Technical Reference All stakeholders will do their part: Content creators will create accessible ICT that conforms to the standards. Accessibility begins with the first word they write in MS Word. Manufacturers of assistive technologies, authoring software, and computer hardware/devices will build their products to conform to the standards. This includes Microsoft, Adobe, Apple, Google, Samsung, Freedom Scientific/JAWS, and other technology manufacturers. End users will learn to use their assistive technologies and understand the standards.