The next step in the Section 508/255 Refresh, and Oracle's public comments

Background

When Congress amended the Federal Rehabilitation Act in 1997, it directed the U.S. Access Board to create a set of Accessibility Standards that would apply to Electronic and Information Technology (E&IT) procured by the U.S. Federal Government (known as the "Section 508 standards"). It further directed the Access Board to periodically refresh these standards.

Likewise when Congress passed the Telecommunications Act of 1996, it directed the U.S. Access Board to develop a set of guidelines for telecommunications accessibility (known as "Section 255 guidelines"). It likewise further directed the Access Board to periodically refresh these guidelines.

In 2006 the Access Board convened the Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) to advise them on a converged set of accessibility provisions to apply to both Federal Procurement (Section 508) and telecommunications more broadly (Section 255). In April, 2008 TEITAC delivered their final report, containing their recommendations for a common set of accessibility provisions to cover both E&IT, and telecommunications products.

The ANPRM

Last March, the Access Board announced the availability of an Advanced Notice of Proposed Rulemaking - an early preview of the their proposed accessibility provisions to cover E&IT and telecommunications (now together also called simply Information Communications Technology or ICT).

This past Monday, the 90-day comment period closed, with more than 150 public comments submitted to regulations.gov. Among those are the public comments from Oracle, primarily authored by myself and Accessibility Program Director Peter Wallack (with contributions gathered from numerous Oracle engineering teams).

To broadly summarize the key Oracle comments (including those from the public hearing in March):

  • The proposed standards significant advance the framework for accessible ICT procurement.

  • Harmonizing with WCAG 2.0 AA is very welcome (and we have specific suggestions to tweek how that is done in the proposed provisions).

  • Recognition of the "dance of three" - platform responsibilities, application responsibilities, and assistive technology responsibilities - is welcome and very important (and we have specific suggestions to tweek how that is accomplished).

  • Formal requirements for tools used to author electronic documents are important (with more specific "tweek" suggestions).

  • Care must be taken with provisions around movie playback and VoIP software. The provisions should not transform general purpose computers that incidentally have such features (e.g. a server with a DVD drive on it, or downloaded Skype software added after the fact) inadvertently into "movie players" and "telephones", which are required to have a "CC" button on them or otherwise meet hardware requirements relating to "telephones".

  • 508 general exception ยง1194.3(f) - the so-called "back office exception" - shouldn't be completely removed. A narrowly tailored exception that would both require all "remote-able" user interfaces to be accessible while allowing physical interaction needed solely for maintenance, repair, or occasional monitoring to be excepted from compliance is important. The design of data centers essentially requires full use of the 8+ feet of height of server racks, necessitating that some switches and other physical controls be out of reach of someone in a wheelchair.

  • The Access Board's recognition that some ICT may receive "patches" to fix bugs or clean up functionality shouldn't trigger a reappraisal of accessibility provisions is welcome. Numerous Oracle customers have stable editions of our products and platforms (e.g. Solaris 8) in production systems that they will continue to maintain for many years into the future - as they have already done for more than a decade. It is important to recognize that the "expected life" of major ICT products can be decades.

Next steps

Now that the Access Board has closed the comment period, it will carefully read and review the thousands of pages of comments they have received. After their thorough analysis of them, they will issued a revised set of proposed provisions - a formal Notice of Proposed Rulemaking. And after another public comment period (and likely another thousand or so pages of comments), a second review and finally issuance of their Final Rule. And soon after that, ICT products procured by the U.S. Federal government (and the many States and Universities that likewise apply 508) - not to mention telecommunications under the jurisdiction of the FCC - will need to meet the updated accessibility provisions.

And while that is some time into the future - already ICT companies are delivering products into the market that meet many of the newly proposed provisions. For example, AOL already has real-time-text support in AOL Instant Messenger. Numerous software video playback products support and decode closed captions. The Java and GNOME platforms (including Solaris and other GNU/Linux environments) - along with the Apple Macintosh and iPhone/iPad, and the RIM Blackberry family of phones - define a rich set of Accessibility Services that are supported by many thousands of applications and which enable assistive technologies to provide access without any need for reverse engineering. And a growing number of websites are already making use of WCAG 2.0 and the emerging WAI-ARIA specification for Rich Internet Application accessibility.

So even though the refresh effort is far from complete, it is already having a profound influence on what is being developed and shipped today!

Comments:

Is there a document or other source that goes into more detail on the "dance of three"? The boundaries seem to becoming more fuzzy. When Apple finally decided to address the issue of accessibility for the blind and visually impaired, they built VoiceOver into the platform itself, thereby to a great extent bypassing the need for an additional layer of assistive technology. It is hoped in some communities that others will follow Apple's lead and build accessibility into the platform itself. How would this affect the "dance of three"? In addition, on the web, what seems destined to become the main platform, shouldn't we speak of a dance of four (platform, application, assistive technologies, and webpage/document designers)? Many accessibility features can become a moot point if the webpage is poorly designed.

Posted by William J. Griffiths on June 26, 2010 at 12:25 PM PDT #

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