1. Presented by: Jonathan Avila Chief Accessibility Officer
Section 508 Revised
Presented by:
Jonathan Avila Chief Accessibility Officer

2. Formerly Known As SSB BART Group
Who is Level Access?
Formerly Known As SSB BART Group
New Corporate Identity – Name and Branding
New Website – Coming Spring 2017!!
No Change in our Innovative Technology or Excellent Service
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3. CSUN 2017 Assistive Technology Conference
Section 508 Overview
Requires Information and Communication Technology (ICT) developed, purchased, used, and maintained by the Federal government to be accessible to people with disabilities
The United States Access Board issues the standards
Required for all US Federal government ICT
Standards Adopted as a best practice for procurement by most US public sector organizations (states)
Standards sometimes applied to programs using Federal funds (Section 504) HHS/CMS, Education, etc.
Section 508of the Rehabilitation Act is the US Federal law requiring that all Electronic and Information Technology, or EIT developed, purchased, used, and maintained by the Federal government needs to be accessible to people with disabilities. Section 508 directly applies to the US Federal government only. The United States Access Board issues the standards. Most US public section organizations adopted Section 508 as a best practice for their procurement processes. Select the Forward button or arrow to learn more about Section 508.
Section 508 refers to a statutory section in the Rehabilitation Act of 1973 (refer to 29 U.S.C. 794d). Congress significantly strengthened Section 508 in the Workforce Investment Act of Its primary purpose is to provide access to and use of Federal executive agencies’ electronic and information technology (EIT) by individuals with disabilities. The statutory language of Section 508 can be found at
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4. CSUN 2017 Assistive Technology Conference
Covered Technology
Includes information technology and any equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, or duplication of data or information. Examples include
Telecommunications products (such as telephones, mobile phones),
Information kiosks and transaction machines,
World Wide Web sites
Electronic documents
Multimedia, and
Office equipment such as copiers and fax machines.
So what constitutes as Electronic and Information Technology, or EIT? EIT needs to be accessible to disabled employees and members of the public. EIT is any information technology and equipment or interconnected system or subsystem of equipment that is used to create, convert, or duplicate data or information. EIT includes telecommunication products such as telephones; information kiosks and transaction machines; World Wide Web sites; Multimedia, such as videotapes; office equipment such as copiers and fax machines, and services.
Select the Forward button or arrow to learn more about examples of technical systems and services covered under Section 508.
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5. ICT Standards and Guidelines
The ICT Standards and Guidelines rule updates and harmonizes Section 508 standards and Section 255 Telecommunication Accessibility Guidelines.
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6. CSUN 2017 Assistive Technology Conference
Timeline
Final rule approved by Access Board and Office of Management and Budget (OMB)
Published in the Federal Register on January 18, 2017
Section 255 guidelines to be effective March 21, 2017
Was March 18, 2017: Executive order put 60-day delay for all regulations that have not yet become effective
Compliance w/ Section 255 Guidelines not required until/ if adopted by FCC
Compliance w/ Section 508 standards January 18, 2018
Federal Acquisition Regulations (FAR) to be updated (anticipated during July 2017)
Address procurement requirements & date by Federal agencies’
GSA to provide guidance on GPAT and other questions
For more on how the government makes rules, check this out:
Board explains that the Federal Acquisition Regulation Council will start their process to incorporate standards & will address
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General Themes
Use consensus based standards when possible
Normalize to WCAG 2.0 as base standard for web, electronic content and software
Harmonize with other international standards and regulations
Focus on functional use profile v. product type
New cognitive Functional performance Criteria added
Define coverage for electronic content
Clarify scope of functional performance criteria
Define AT interoperability requirements
Define requirements of authoring tools
Generally bring the standard up-to-date with the modern era
Refresh hardware standards to permit front facing access
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8. Harmonization and Standards
Focus on voluntary international consensus standards for core technical requirements
Idea – Bigger accessibility market = better, more accessible solutions
Idea – One global accessibility standard
Harmonize with other web and electronic content standards (Australia, New Zealand, Canada, Japan, Germany, France)
Harmonize with international standards such as the European Union’s EN  standard for public procurement of ICT 
Ten referenced standards
Ten referenced standards
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Standards Structure
Overall
Scoping requirements
Reference electronic content, documents, and software
Functional performance criteria
Hardware
Software (includes web applications)
Support Documentation and Services
Referenced standards
Requirements of all relevant technology apply
For example, a mobile phone contains hardware, software and content all in one product
Overlap of product requirements a point of much confusion in the current standards
Validate a system based on all relevant technical requirements
Clarify the set of standards that will apply to a system
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10. Important Notes from Access Board Webinar
Used, maintained, or procured unaltered & compliant before January 18, 2018 falls under the safe harbor for Section 508
Safe harbor applies on a component/element basis
Altered includes change of UI, data, or interoperability
Security patch for web site that doesn’t change UI/data = not altered
Previously non-compliant ICT aren't covered under Safe Harbor
ICT under development but not yet used by January 18, does not fall under Safe harbor
Individual agencies still have flexibility in implementing and regulating revised Section 508 standard under Rehab Act
Current Section 508 standards still relevant – even after January 18, 2018 for evaluating existing non-updated ICT
Section 255 guidelines that mobile apps integral to use & has a UI that it must conform to requirements
Section 255 guidelines have no safe harbor
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What is Not Included
Real-time text (RTT) requirement reserved for later
FCC has adopted RTT allowance for wireless providers using VOIP
FCC has requested information on loosening need for TTY compatibility as RTT is more widely adopted
TTY support is not in Section 508 refresh - in transition with real-time text - will update- TTY compatibility is covered by Section 255 guidelines
Under 255 TTY compatibility is still required w/ support for emergency call
Reference to PDF/UA-1 as a way to meet revised standards for PDF is not included in final rule
PDF/UA may still be useful in assessing WCAG 2.0 conformance & may be required for authoring tools
Section 255 mobile phones won't be required to have TTS output.
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Applicability of WCAG 2.1
WCAG 2.1 FPWD just published (Tuesday 2/28/17)
28 Proposed SC target mobile, low vision, and cognitive, e.g.
Touch target size
Gesture with assistive technology
Accidental activation
Conformance with WCAG 2.1 means conformance w/ WCAG 2.0
WCAG 2.1 would not be required by revised standards unless included by reference by the US Access Board
Process for inclusion would be straightforward due to the way the standards are referenced`
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Applying WCAG
Conformance and functional requirements
Key take away for electronic content, web, software, documents, use WCAG 2.0 Level A and AA
Also includes WCAG Conformance Requirements
Compliance-Level, Full-Page, Complete process, Accessibility Supported, and non-interference (guidance on alternatives)
Applies to non-web docs & software (desktop or mobile) through lens of Guidance for applying WCAG to non-web ICT document
4 primary exceptions (multiple ways, bypass blocks, consistent navigation, & consistent navigation) some differences such as set of documents rather than set of pages.
Keyboard interface support is required even for mobile
Don’t actually have to make a formal WCAG conformance claim
Examine sufficient techniques and documented failures
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14. Functional Performance Criteria
Functional performance requirements only apply in situations where:
A technology standard/guideline does not exist to address the situation
As an equivalent manner to meet the standards when a technique standard cannot be met
Theoretically a safe harbor for products that are technically compliant but not usable by people with disabilities
Practically unlikely to be the case
Remaining functional performance criteria tweaked for clarity
E.g. With Limited Vision. Where a visual mode of operation is provided, ICT shall provide at least one mode of operation that enables users to make use of limited vision.
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15. Functional Performance Criteria
New Criteria
Without Perception of Color. Where a visual mode of operation is provided, ICT shall provide at least one visual mode of operation that does not require user perception of color.
With Limited Manipulation. Where a manual mode of operation is provided, ICT shall provide at least one mode of operation that does not require fine motor control or simultaneous manual operations.
With Limited Reach and Strength. Where a manual mode of operation is provided, ICT shall provide at least one mode of operation that is operable with limited reach and limited strength.
With Limited Language, Cognitive, and Learning Abilities. ICT shall provide features making its use by individuals with limited cognitive, language, and learning abilities simpler and easier
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16. Electronic Documents – Public Facing
Arguably covered under the current standards but interpretations vary
All public facing content covered
Internal “official agency business” covered
Content is broadly defined – includes agency websites, blog posts, social media sites, s and the like
Official content posted on non- agency URL seems to be covered
Alternative can be provided for inaccessible third party content
Includes third party content and social media. Alternatives can be provided.
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17. Electronic Documents – Not Public Facing
Agency Official Communication -- content includes the following:
An emergency notification;
An initial or final decision adjudicating an administrative claim or proceeding;
An internal or external program or policy announcement;
A notice of benefits, program eligibility, employment opportunity, or personnel action;
A formal acknowledgement or receipt;
A survey questionnaire;
A template or form; or
Educational or training materials.
Intranet web content designed
Narrow archival exception – can’t be publicly available
This pertains to Agency Official Communication
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18. Electronic Documents – Technical Standards
WCAG 2.0 A and AA
Authoring tools also covered
If PDF export has option for PDF PDF/UA must be supported.
A system that can generate covered content needs to support the generation of accessible content
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19. Interoperability Requirements
ICT must be interoperable or compatible with documented features of assistive technology and accessibility features
Applies to software, tools, and platforms
Not applicable to web apps – WCAG 2.0 safe harbor
Would apply to mobile apps
Would apply to mobile hybrid apps
General focus: use operating system APIs and standard system accessibility functions when available
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20. Documentation and Support
Product supporting documentation - notably product documentation - must now clearly conform to WCAG A & AA requirements
Exceptions for 4 WCAG SC – bypass blocks, multiple ways, consistent identification and consistent navigation
Includes web based service and support
Provide alternative formats for individuals that are blind or low vision on request
Only applies when non-electronic documentation is provided.
Provide overview of accessibility and compatibility features
Support services support the communication needs of people with disabilities
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21. Standards in current Section 508 not in/ different from WCAG 2.0
Section Web
WCAG 2 Level A/AA
Comments
Twice per second flashing limit – no exception for size. Allows for flashing in the range from times per seconds
WCAG’s is 3 times per second and also allows for small areas to contain flashing content. 
Practically equivalent
Require that documents are readable without associated style sheets
Only requires that content is in a meaningful sequence
More flexibility
Requires that embedded and linked non-HTML media provide a link to an accessible plug-in
Indicates that the technology relied upon for conformance are accessibility supported.
Most agencies will likely still be providing links to plug-ins – if not on every page on some general page
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22. Standards in current Section 508 not in/ different from WCAG 2.0 (cont.)
Section Web
WCAG 2 Level A/AA
Comments
Requires that alternative pages are not used unless cannot be made accessible  
WCAG allows for alternative pages to be used but has no bar to determine when or when they are not allowed
Unclear how strictly this was followed previously. Could be addressed by agency requirements.
In our experience most US Federal agencies require that link text is meaningful when taken out of context even though it’s not explicitly in Section 508.
WCAG AA allows for it to be understood in context. Out of context is a WCAG AAA requirement.
Some agencies will likely want to address this in their checklists.
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23. Voluntary Product Accessibility Template
Beta VPAT 2.0 introduced by ITI
Includes revised Section 508, WCAG 2.0, and EN
Includes references between shared standards
Provided updated guidance on how to complete the document
Other non-federal public sector people seeking open VPAT type document as well
GSA has GPAT document that historically has been equivalent – this will likely be updated and focus just on the revised Section 508 standards.
GPAT docs helped to clarify which standards were applicable for different product functions based on product type
Benefits
Success criteria are understood through non-normative techniques and understanding documents that can change
As technologies change new ways to implement are available
Implement through Sufficient Techniques and Failures
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24. Likely Agency Technical Approach
Update checklist (document, web, software)
Most agencies have their own checklist breaking down what the standards mean
E.g. VA, DHS, HHS, SSA
Many checklists already incorporated some WCAG 2.0 SC
Some agencies apply current software standards to web while others do not
Federal baseline includes (a), (c), (h)
Simplifies approach as same standards are applied across documents, web, and software
Checklist may be used in procurement process
For most non-hardware non-authoring tool content the focus will be support for WCAG 2 A/AA and conformance requirements
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Questions?
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26. CSUN 2017 Assistive Technology Conference
Contact Information
Jonathan Avila Chief Accessibility Officer
Follow
@SSBBARTGroup
linkedin.com/company/ SSB-BART-Group
facebook.com/ SSBBARTGroup
SSBBARTGroup.com/blog
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Resources
Web Content Accessibility Guidelines (WCAG) 2.0
Guidance on applying WCAG to Non-Web ICT
Comparison Table of WCAG 2.0 to Existing 508 Standards
standards/communications-and-it/about-the-ict- refresh/background/comparison-table-of-wcag2-to-existing-508- standards
Understanding WCAG 2.0
Techniques for WCAG 2.0
VPAT Beta 2.0
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