We were recently told by a contracting officer that access to an on-line database was not Electronic and Information Technology (EIT) and therefore not subject to Section 508. This is clearly wrong. The web interface that the government agency would be using as a result of the purchase is applicable to Section 508 1194.22 Web-based internet information and applications (as well as functional performance criteria. When the government makes a purchase and as a result their employees or the general public will be interacting with EIT, then Section 508 applies. Even if the software doesn’t sit on computers at a government site, the website interface applies. Don’t forget that you may need to look at the interface for regular users and also user administration.
A related example is Cloud Computing. Have you come across similar examples that you can share?
We also have more posts in our “Is it EIT?” category. Please let us know your thoughts on this question.
Recently, a new set of Quick Links about ebooks were added to BuyAccessible.gov. Quick Links contain solicitation language and a Government Product Accessibility Template (GPAT) for a specific deliverable, in this case an ebook. There are also Quick Links for ebook readers and ebook software.
The GPAT for ebooks will let you know what Section 508 technical provisions most likely apply to ebooks. For example most of the provisions in Section 1194.22 Web-based intranet and Internet information and applications apply. You can use this information to include in your solicitation requirements when making a purchase, or in your design requirements when creating an ebook.
How many Electronic and Information Technology (EIT) products that you buy include product support information on the Internet? We are willing to guess many of them! When product support information is provided on the web for products that are likely to be used by government staff, then that information is EIT subject to Section 508 Subpart D — Information, Documentation, and Support (Section 1194.41). Since the support material is delivered over the Internet, the provisions of Section 1194.22, Web-based intranet and internet information and applications, are also applicable. If the support materials include video, then that video is also subject to the provisions of Video and Multimedia Products (Section 1194.24). It is important to let vendors know about these agency requirements in your solicitations.
For example, if you are buying a printer that has product support documentation on the web, you need to require that the printer vendor supply documentation as to how their on-line documents conform to the Section 508 guidelines for web documentation.
Vendors are developing kiosk software that allows users to perform information technology functions, such as browse the web, make telephone calls via VoIP, word process and everything else a personal computer can do, but in a virtual computing environment. Are these information kiosks or personal computers?
From a Section 508 accessibility requirements standpoint it doesn’t really matter. The same requirements would apply. Requirements from 1194.25 Self-contained Closed Systems that are not included in 119.26 Desktop and Portable Computers are covered in 1194.21 Software and Operating Systems and 1194.22 Web-based Intranet and Internet Information and Applications. Other requirements are included in 1194.31 Functional Performance Criteria.
When you hear the term “kiosk”, what do you think of? A booth in the mall that sells fuzzy mittens, cell phones, or soft pretzels? Another type of kiosk is the electronic kind, for example airport check-in kiosks. Electronic and Interactive Kiosks contain a computer terminal that performs a function without letting users access system functions. Government agencies have also been creating kiosks to provide information to people as well as interactive kiosks that provide government services. For example the US Post office has kiosks that allow you to weigh those holiday packages, pay for postage, and print shipping labels. Virginia’s State parks have kiosks that allow you to see videos of trails and print maps. The US Department of Homeland Security also created kiosks for visitor registration upon entering the US.
We were recently asked by a vendor if Section 508 applies to electronic kiosks. Kiosks, in fact, are included in the definition of EIT by the Access Board and in the definition of self-contained, closed products so Section 508 clearly applies. But, as usual this question led to another, namely what provisions would apply to kiosks. On the surface, this looks easy, but in fact kiosks illustrate the complexity of technical provisions and how technical and accessibility requirements evolve over time.
A kiosk as a self-contained, closed product is a devices unto itself. It is expected to provide all required accessibility as a standalone unit without the support of external assistive technology. Software is generally embedded, built into the electronics of the kiosk. Inputs are typically provided by keyspads/keyboards or touchscreens. Outputs are typically audible or visual. Accessibility requirements for such a kiosk are defined in 1194.25 Self-contained, Closed Products; 1194.23 k1-4 as part of Telecommunications Products; and 1194.31 Functional Performance Criteria. Further, 1194.41 Information, Documentation, and Support would also apply to any support documentation that came with the kiosk. Finally, if the kiosk also includes software to configure and maintain the kiosk, then 1194.21 Software Applications and Operating Systems could also apply.
We got a call the other day from a government user of the BuyAccessible Wizard about 2-way radios. We don’t get a lot of requests for information on 2-way radios, so we had to think a little. Our conclusion is, yes, 2-way radios are Electronic and Information Technology (E&IT); essentially, they are similar to mobile telephones. We then did our usual search for product accessibility information and found none.
So what are the accessibility features of 2-way radios? The features include many of the provisions from 1194.23 Telecommunications Products. Provisions from 1194.21, 1194.22, and 1194.26 clearly do not apply. Provisions from 1194.31 Functional Performance Criteria (FPC) apply to all products.
Two-way radios have fewer features than mobile phones and do not directly interconnect with the telephone network. It would be a fundamental alteration for a radio to use the baudot signals used by TTYs and therefore it cannot be expected for a 2-way radio to support TTY signals or provide a non-acoustic connection point for TTYs. Likewise, 2-way radios do not provide many other telephone-like services such as voice mail and Caller ID. Therefore, provisions a, b, c, d, e, and j from 1194.23 are not applicable. All other provisions in 1194.23 (f, g, h, i, and k) are applicable to available features of higher end model two-way radios. The FPC will be satisfied by these higher-end models as well.
Now all we have to do is get government buyers to recognize that 2-way radios are subject to Section 508 and get vendors to provide accessibility information about the features of their products!
Almost all solicitations for software license renewals that we review ignore Section 508 requirements. Typical software license renewals include software maintenance and support services, which are subject to Section 508 requirements.
Maintenance services can affect the accessibility features of the subject software. If 508 requirements are not included in the license agreement, the results could be maintenance upgrades, patches, etc that interfere with existing accessibility features. If 508 is included, patches and upgrades could be developed to improve accessibility.
Continue reading “You know that software is subject to Section 508 requirements, but what about renewing a software license?”
How often do your contractors or internal staff create information deliverables, like reports, that you intend to put on the web? If you plan to make reports available through a link on website, then it becomes subject to Section 508 Provisions from 1194.22, 1194.31, and 1198.41(a) apply.
- 1194.22 Web-based Intranet and Internet Information and Applications- Some of its provisions apply to reports on the web, for example (a) providing text equivalents for non-text elements like images, (c) information conveyed with color is also available without color, (g) row and column headers for data tables, and (n) making electronic forms accessible
- 1194.31 Functional Performance Criteria- Need to assure that the document can be used with assistive technology like a screen reader.
- 1194.41(a) Information, Documentation, and Support- Reports should be provided alternate formats upon request
Additionally, if the report contains interactive elements, then 1194.21 Software and Operating Systems also applies.
Here are some reference materials that may be helpful:
Are conferences Electronic and Information Technology and subject to Section 508? On one hand, accommodation for attendees with disabilities is not Section 508. Those accommodations are covered by ADA. On the other hand, websites and presentations, webinars, and other electronic information distributed as part of the conference are subject to Section 508. For example if you have a website for registration and publishing the agenda, that website needs to be Section 508 compliant. Also if you publish presentations on the web after the conference, those documents need to be Section 508 compliant.
Here is a past post we wrote about accessible presentations. Some key points are: to ask attendees about accommodation needs and provide for them; remind speakers to repeat what is displayed on any screen in case any audience member can’t see it; and requiring everyone to use a microphone.
Accessibility of buildings, while not covered by Section 508, is also important. You can learn more about it from the Access Board website.
There is free training available on accessible conferences through the Section 508 Universe. You can register for a Section 508 Universe account here.