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In my last two posts ( I gave an overview of the US Access Board’s (“The Board”) latest proposal to update the Information and Communication Technology (ICT) Standards and Guidelines related to Section 508 (“The Refresh”) and detailed some of the proposed updates in The Refresh.  In this final post in the series I’ll share some areas in the proposed update which I believe will require further clarification from The Board.

Requirement of PDF/UA-1 Conformance

It would appear that agencies can choose PDF/UA or WCAG 2 Level A/AA for conformance for PDF documents.  If that is not the case clear guidance should be given that PDF/UA is required for PDF.  The Board should also consider that PDF/UA does not provide an equivalent level of accessibility for all success criteria within WCAG 2 Level A and AA.  For example, PDF/UA does not specifically require sufficient contrast; and while it requires an alternative for use of color it does not require the alternative be available visually.  Having a visual equivalent for color is crucial for people with color perception disabilities such as color blindness.   Other areas such as multimedia and dynamic content are not fully addressed by PDF/UA and defer back to WCAG for conformance.  When PDF/UA-1 is used to determine compliance with the standards and guidelines, the relevant WCAG success criteria that are not covered by PDF/UA need to be evaluated and this information should be documented in the final rule.

VPAT and Conformance Documents

Undoubtedly the Voluntary Product Accessibility Template (VPAT) and Government Product Accessibility Template (GPAT) documents will need to be updated. The Information Technology Industry Council (ITI) will be updating the VPAT which is a copyrighted document.  It would seem that GPAT would likely be updated by the General Services Administration (GSA) once the refreshed standards are published.  It is unclear at this point if these documents will contain the WCAG success criteria or reference other WCAG conformance statement documents.  It may be helpful to have input from the Access Board in developing these materials so that there is a clear and consistent way showing that standards incorporated by reference are met.

Use of Standards that Must be Purchased

It appears that six out of the ten voluntary consensus standards do not require purchase.  Three additional standards organizations have said they would make available upon request during the comment period and one of the standards PDF/UA to this point must be purchased to access within or outside of the comment period.

The use of standards that must be purchased raises certain challenges The Board should consider.  For example, organizations must purchase the standard in order to determine whether they meet the standard.  This can increase the cost for organizations selling into the government.  In addition, organizations that make tools or platforms that manage accessibility (e.g. AMP) will need to reference the standards in their products.

Third Party Content and Social Media

There is some ambiguity on third party content such as social media that agencies have control over and the requirements for alternatives.  The only place that social media is mentioned in the proposed rule is under the definition of public-facing.  This implies that social media would be covered under the agency official communication electronic content requirements, however, many social media sites which are outside of direct government control are not accessible.  Some agencies have taken stances to require that government sites provide the same mission critical information on their site in addition to social media postings.  It would be helpful to have some guidance from The Board on this matter.

Authoring Tool Additions

Authoring tool accessibility standards were added to the software chapter to make sure the authoring environment is accessible and the content that is generated/created from the tool is accessible.  This includes provisions requiring accessible templates to the degree the destination format supports accessibility.  The addition of these standards is applauded and hopefully will have a significant impact on the accessibility of generated content both for app and user generated content such as blogs and social media posts.  The authoring tool standards are limited and do not cover all of the Authoring Tool Accessibility Guidelines (ATAG) in the current candidate recommendation.

Hardware Standards Update

A number of new hardware requirements have been introduced.  The standards address areas such as contrast, new lower reach requirements, an additional forward reach requirement, knee space, screen location, screen tilt and others.   The updated and internationally harmonized hardware requirements will hopefully mean increased access by people with motor impairments including people who use wheelchairs and scooters, as well as people with reach and strength limitations.  One area that I did not see addressed is the implication of screen tilt and height for people with low vision.  Screen placement and the tilt in relations to lighting and glare can have a huge impact on access by people with low vision.  I’ve run into some situations were screens are too far away and other instances where they were too low to the ground requiring a person with low vision to sit on the ground in order to see the screen.  The Board should make sure that these standards related to screen position provide customizable and equitable access to all people with disabilities.

Clarifying the Back Office Exemption

The Board has finally addressed the confusion surrounding the back office exemption.  The current Section 508 contains a back office exemption stating that E&IT only accessed by maintenance personnel did not have to meet the Section 508 requirements.  Many vendors assumed this applied to servers and their remote interfaces as well, but this was never the intention of The Board.  The Board has clarified that the remote interfaces do need to be accessible — the exemption only applies to controls that are located in in maintenance areas.  In my experience, vendors should also consider that just because a machine is a server no longer means that the server will be installed in a maintenance personnel only area.  Many developers and IT administrators have servers at the desk and thus vendors do not know where the server will be deployed and thus may not automatically take an exemption for the physical controls either.

Submitting Comments

The Board is seeking public comments on the rule as well as a preliminary assessment of its estimated costs and benefits. Comments are due by May 28, 2015.

Further information about the proposal is available on the Access Board’s ICT Refresh page or by contacting Timothy Creagan at (202) 272-0016 (v), (202) 272-0074 (TTY), or

Comments can be submitted or viewed through the website. The proposed rule includes instructions on submitting comments.

For further information, visit the Board’s website.