Recently someone asked, “Is a VPAT form needed for a replacement hard drive for an existing server?”
Although a replacement internal hard drive is EIT, no technical provisions or functional performance criteria from the Section 508 standards apply, since this is an internal component with no direct interface to the user. (There are provisions, however, that apply to external hard drives.)
However, the server, as a whole, should be reviewed against the Section 508 requirements. An individual agency’s procurement policy will dictate whether a VPAT from the vendor is necessary to meet the agency’s requirements for due diligence under Section 508. A sample VPAT template for servers is available under the recently released BuyAccessible Quick Link for servers.
On March 22, 2010, the Access Board released an Advance Notice of Proposed Rulemaking (ANPRM), as well as draft text of the proposed standards and guidelines, seeking comment on the proposed revisions to the Section 508 accessibility standards and Section 255 telecommunications accessibility guidelines. The rulemaking process started in September 2006 with the Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) reviewing the Section 508 Standard and Section 255 Telecommunications Guidelines and recommending changes. TEITAC presented a report of recommendations to the Access Board on April 3, 2008. This report served as input to the Access Board, which worked with an ad hoc committee of Board members and staff from several Federal agencies to develop the Advanced Notice of Proposed Rule Making (ANPRM) to solicit public comment.
So what happens next?
Continue reading “When will Section 508 be updated?”
This week an interesting post was made on the Disability Blog published by Disability.gov called, “The Refresh of the Section 508 Standards.”
One of the more interesting questions received lately is: “Are GPS units subject to Section 508?”
We believe the answer is YES, a hand held GPS unit is EIT based on the Access Board definition and therefore Section 508 does apply. A GPS unit is information technology (or equipment or interconnected system or subsystem of equipment) that is used in the creation, conversion, or duplication of data or information. See the related post What is EIT?
A typical follow-up question is: “Since someone with limited vision would not need a GPS, can we assume the technical provisions for visual accessibility don’t apply?”
The answer to this is clearly NO. It is important to remember that the abilities of the person using the product are not a consideration in determining the relevance of Section 508. Also a person with limited vision can find a GPS extremely important for walking and other navigation.
Are you looking for assistance in ensuring your solicitation is compliant with Section 508? We can help.
The General Services Administration (GSA), as part of their statutory requirement to provide technical support for Section 508 of the Rehabilitation Act of 1973, assesses the extent to which agency solicitations properly consider Section 508 standards by sampling postings on FedBizOpps. Federal Acquisition Regulation (FAR) – Acquisition of Information Technology Subpart 39.2 states that Section 508 must be addressed in any solicitation to procure Electronic and Information Technology (EIT). For more information, refer to the Office of Management and Budget (OMB) memo entitled “Ensuring the Accessibility of Federal Electronic and Information Technologies Procured by Federal Agencies”.
Continue reading “How Compliant is Your Solicitation?”