R 221301Z MAR 01
FM CMC WASHINGTON DC//C4//
TO MARADMIN
INFO DON CIO WASHINGTON DC
BT
UNCLAS //N01000//
MARADMIN 140/01
MSGID/GENADMIN/CMC WASHINGTON DC/C4//
SUBJ/ELECTRONIC AND INFORMATION TECHNOLOGY ACCESSIBILITY STANDARDS//
REF/A/DOC/FEDERAL ACCESS BOARD/21DEC2000/NOTAL//
REF/B/MSG/ALNAV 018-01, 152200Z MAR 01/YMD:20010315//
NARR/REF A IS THE FINAL ELECTRONIC AND INFORMATION TECHNOLOGY (EIT)
ACCESSIBILITY STANDARDS FOR DISABLED PERSONS. REF B ANNOUNCES THE
DEPARTMENT OF THE NAVY APPROACH TO IMPLEMENTATION OF SECTION 508
COMPLIANCE STANDARDS.//
POC/M. ONEAL/MAJ/C4/-/TEL:DSN 223-3518/EMAIL:ONEALMS@HQMC.USMC.MIL//
RMKS/1. IN 1998, CONGRESS AMENDED THE REHABILITATION ACT OF 1973 AND
STRENGTHENED PROVISIONS COVERING ACCESS TO FEDERAL INFORMATION AND
SERVICES BY PEOPLE WITH DISABILITIES. THE AMENDMENT, HEREAFTER
REFERRED TO AS SECTION 508, REQUIRES FEDERAL AGENCIES TO ENSURE THAT
ELECTRONIC AND INFORMATION TECHNOLOGIES (EIT) (AS DEFINED BY THE
CLINGER-COHEN ACT OF 1996) THAT AGENCIES DEVELOP, PROCURE, MAINTAIN,
OR USE ARE ACCESSIBLE TO FEDERAL EMPLOYEES AND MEMBERS OF THE PUBLIC
WITH DISABILITIES. THE EIT ACCESSIBILITY STANDARDS WERE PUBLISHED BY
THE ARCHITECTURAL AND TRANSPORTATION COMPLIANCE BOARD ON 21 DEC 00.
THESE STANDARDS ARE ENFORCEABLE BEGINNING 21 JUN 01, AFTER WHICH THE
POTENTIAL EXISTS FOR ANY INDIVIDUAL WITH A DISABILITY TO FILE A
COMPLAINT OR PURSUE CIVIL ACTION AGAINST AN AGENCY ABOUT ANY
TECHNOLOGY HE OR SHE CANNOT ACCESS OR USE. ALTHOUGH THE FOCUS OF
THIS LEGISLATION IS ON FUTURE EIT, LEGACY EIT THAT WILL BE USED
DURING THE FORESEEABLE FUTURE ALSO FALLS UNDER THESE PROVISIONS. ANY
EIT THAT IS PROCURED ON OR AFTER 21 JUN 01 MUST MEET THE
ACCESSIBILITY STANDARDS, UNLESS AN EXEMPTION IS APPLICABLE (SEE PARA
5).
2. SINCE THE PUBLISHING OF THE COMPLIANCE STANDARDS, THE DEPT OF THE
NAVY CHIEF INFORMATION OFFICER (DON CIO), IN COORDINATION WITH HQMC
C4 AND CNO N-6, HAS BEEN DEVELOPING A PLAN OF ACTION FOR
IMPLEMENTING THESE STANDARDS ACROSS THE DEPARTMENT. ALSO, DON CIO IS
IN THE PROCESS OF DEVELOPING AN ASSESSMENT TOOL THAT PROVIDES A
COMPREHENSIVE VIEW OF A WEB PAGE'S OR IT SYSTEM'S COMPLIANCE STATUS.
WHEN AVAILABLE, THIS TOOL WILL BE PROMULGATED ACROSS THE DEPARTMENT.
3. CURRENTLY, THERE IS NO ADDITIONAL FUNDING ALLOCATED OR PLANNED
FOR THIS EFFORT. THE DOD COMPUTER/ELECTRONIC ACCOMMODATIONS PROGRAM
(CAP) WILL PROVIDE ASSISTIVE TECHNOLOGY (E.G., TELETYPEWRITERS,
SPEECH AND BRAILLE OUTPUT SYSTEMS, ETC.) AND SERVICES TO ENSURE
FEDERAL EMPLOYEES WITH DISABILITIES HAVE EQUAL ACCESS TO EIT. THE
CAP HOME PAGE IS HTTP:DOUBLE SLASH WWW.TRICARE.OSD.MIL/CAP.
4. APPLICABILITY. SECTION 508 APPLIES TO THE FOLLOWING EIT:
A. COMPUTERS AND NETWORKS (E.G., HARDWARE, SOFTWARE, WEB PAGES,
EMAIL)
B. INFORMATION AND TRANSACTION MACHINES (E.G., ATM AND FARE CARD
MACHINES)
C. EQUIPMENT USED FOR TRANSMITTING, RECEIVING, USING, OR STORING
INFORMATION (E.G., FAX MACHINES, COPIERS, TELEPHONES, CALCULATORS)
5. EXEMPTIONS. EXEMPTIONS TO SECTION 508 REQUIREMENTS ARE:
A. NATIONAL SECURITY SYSTEMS AS DEFINED IN SECTION 5142 OF THE
CLINGER-COHEN ACT OF 1996 (NOTE: SYSTEMS THAT ARE USED FOR ROUTINE
ADMINISTRATIVE AND BUSINESS APPLICATIONS, INCLUDING PAYROLL,
FINANCE, LOGISTICS, AND PERSONNEL MANAGEMENT APPLICATIONS, ARE NOT
EXEMPT.)
B. UNDUE BURDEN (E.G., SIGNIFICANT DIFFICULTY OR EXPENSE) - AN
EXCEPTION MAY BE APPLICABLE IF COMPLIANCE IMPOSES AN UNDUE BURDEN;
HOWEVER, THE ORGANIZATION MUST PROVIDE JUSTIFICATION AND AN
ALTERNATIVE MEANS OF ACCESS. IN DETERMINING AN UNDUE BURDEN, AN
AGENCY SHALL CONSIDER ALL AGENCY RESOURCES AVAILABLE TO THE PROGRAM
OR COMPONENT FOR WHICH THE PRODUCT IS BEING DEVELOPED, PROCURED,
MAINTAINED OR USED.
C. COMMERCIAL NONAVAILABILITY - WHEN ACQUIRING COMMERCIAL ITEMS, AN
UNDUE BURDEN DETERMINATION IS NOT REQUIRED TO ADDRESS STANDARDS THAT
ARE NOT YET AVAILABLE IN THE COMMERCIAL MARKETPLACE IN TIME TO MEET
THE AGENCY DELIVERY REQUIREMENTS. THE REQUIRING OFFICIAL MUST
DOCUMENT THE NONAVAILABILITY AND PROVIDE THE DOCUMENTATION TO THE
CONTRACTING OFFICER FOR INCLUSION IN THE CONTRACT FILE.
D. EIT THAT IS ACQUIRED BY A CONTRACTOR INCIDENTAL TO A CONTRACT
E. PRODUCTS LOCATED IN SPACES FREQUENTED ONLY BY SERVICE PERSONNEL
FOR MAINTENANCE, REPAIR OR OCCASIONAL MONITORING OF EQUIPMENT
F. ACCESSIBILITY-RELATED SOFTWARE OR ATTACHMENT OF ASSISTIVE
TECHNOLOGY DEVICES AT WORKSTATIONS OF FEDERAL EMPLOYEES WITHOUT
DISABILITIES
G. PRODUCTS OR SERVICES WHERE MEETING THE STANDARD WOULD REQUIRE
FUNDAMENTAL ALTERATION TO THE BASIC CHARACTERISTICS OR PURPOSE OF
THE PRODUCT OR SERVICE ITSELF
H. LEGACY SYSTEMS THAT DO NOT REQUIRE MAINTENANCE AND/OR ARE NOT
ALTERED OR UPGRADED, OR ARE SCHEDULED TO BE REPLACED (I.E., A
REPLACEMENT SYSTEM IS IN DEVELOPMENT)
6. EACH MARFOR AND SEPARATE MAJOR COMMAND (E.G., MCCDC, MATCOM,
MARCORSYSCOM, ETC.) IS DIRECTED TO ASSIGN A POINT OF CONTACT (POC)
FOR SECTION 508 COMPLIANCE ACTIONS AND PROVIDE POC INFORMATION TO
THE C4 POC LISTED ABOVE NLT 2 APR 2001. COMMAND/ORGANIZATION POCS
SHOULD BE INDIVIDUALS OF SIMILAR RANK AND EXPERTISE AS THOSE
PREVIOUSLY ASSIGNED TO Y2K COMPLIANCE. ADDITIONALLY, ALL
COMMANDS/ORGANIZATIONS WITH A WEB SITE AND/OR EIT PROCESSES THAT
FALL WITHIN THE SCOPE OF SECTION 508 SHOULD ASSIGN A POC FOR SECTION
508 COMPLIANCE AND SHOULD COORDINATE THEIR COMPLIANCE ACTIONS VIA
THEIR CHAIN OF COMMAND.
7. DUE TO THE SCOPE OF THIS EFFORT, IT IS ENVISIONED THAT THE
MARINE CORPS WILL NOT BE IN COMPLETE COMPLIANCE BY THE 21 JUN 01
DEADLINE. HOWEVER, A GOOD FAITH EFFORT MUST BE UNDERWAY. TO THAT
END, EACH MARFOR AND SEPARATE MAJOR COMMAND (E.G., MCCDC, MATCOM,
MARCORSYSCOM, ETC.) IS DIRECTED TO ASSESS THE IMPACT OF MEETING
THESE COMPLIANCE STANDARDS. THE RESULTS OF THIS ASSESSMENT SHOULD BE
FORWARDED TO THIS OFFICE BY 30 MAY 01. THIS ASSESSMENT SHOULD
ADDRESS THE FOLLOWING AREAS, AT A MINIMUM: FINANCIAL IMPACT;
OPERATIONAL IMPACT; ANTICIPATED LEVEL OF EFFORT: IMPACT ON
PROCUREMENT POLICIES AND PROCEDURES. PROCUREMENT ACTIONS CURRENTLY
UNDERWAY THAT MAY BE APPROVED ON OR AFTER 21 JUN 01 WILL NEED TO BE
ADJUSTED TO INCLUDE THE APPROPRIATE COMPLIANCE LANGUAGE. COMMANDS
WILL ALSO NEED TO REVIEW/UPDATE THEIR COMPLAINT AND REPORTING
PROCEDURES FOR ACCESSIBILITY-RELATED ISSUES, SEE HTTP:DOUBLE SLASH
WWW.USDOJ.GOV/CRT/COR/COORD/INVMANUAL.HTM.
8. SHORT-TERM REQUIREMENT.
A. THE DEPARTMENT OF JUSTICE (DOJ) IS REQUIRED TO SUBMIT A BIENNIAL
STATUS REPORT TO THE PRESIDENT AND CONGRESS REGARDING AGENCIES'
PROGRESS TOWARD IMPLEMENTATION OF SECTION 508. THE FOCUS OF THIS
YEAR'S DOJ SURVEY IS THE ACCESSIBILITY OF FEDERAL AGENCIES' WEB
SITES. THE DOJ HAS TASKED DEPARTMENTS/AGENCIES TO SURVEY TWENTY HIGH
USE WEB SITES. WITHIN THE DON'S REQUIREMENT, FIVE USMC WEB SITES ONLY
HAVE BEEN IDENTIFIED TO COMPLETE THIS SURVEY. THESE WEB SITES ARE:
(1) USMC OFFICIAL WEB SITE - HTTP:DOUBLE SLASH WWW.USMC.MIL
(2) MARINE CORPS SYSTEMS COMMAND - HTTP:DOUBLE SLASH
WWW.MARCORSYSCOM.USMC.MIL
(3) MARINE FORCES PACIFIC - HTTP:DOUBLE SLASH WWW.MFP.USMC.MIL
(4) MARINE CORPS UNIVERSITY - HTTP:DOUBLE SLASH WWW.MCU.USMC.MIL
(5) MARINE CORPS BASE CAMP LEJEUNE - HTTP:DOUBLE SLASH
WWW.LEJEUNE.USMC.MIL
B. THE DOJ SECTION 508 HOME PAGE IS LOCATED AT HTTP:DOUBLE SLASH
WWW.USDOJ.GOV/CRT/508/. INSTRUCTIONS AND AN ELECTRONIC COPY
OF THE SURVEY CAN BE FOUND AT HTTP:DOUBLE SLASH
WWW.USDOJ.GOV/CRT/508/WEB.HTM. IN ORDER TO COMPLETE THIS SURVEY, A
USER NAME AND PASSWORD WILL BE FORWARDED TO THE RESPECTIVE COMMANDS
WITH PURVIEW OVER THESE WEB SITES. THESE COMMANDS ARE DIRECTED TO
FORWARD POCS FOR THESE WEB SITES TO THE C4 POC LISTED ABOVE NLT
2 APR 2001. THE USER NAME AND PASSWORD WILL BE PROVIDED UPON THIS
OFFICE RECEIVING POC INFORMATION. WEB MASTERS OF THESE FIVE WEB
SITES ARE DIRECTED TO COMPLETE THE SURVEY ELECTRONICALLY NLT 5 APR
2001 AND INFORM THIS OFFICE VIA EMAIL WHEN THIS ACTION IS COMPLETE.
OTHER WEB MASTERS ARE ENCOURAGED TO REVIEW THIS SURVEY IN ORDER TO
OBTAIN A BETTER UNDERSTANDING OF THE SCOPE OF THIS EFFORT AND THE
PROCESS FOR MEETING THE COMPLIANCE STANDARDS. ALL WEB MASTERS
SHOULD BEGIN IMMEDIATELY TO ASSESS THEIR WEB SITES FOR COMPLIANCE
AND WORK TOWARD MAKING THEIR WEB SITES COMPLIANT BY 21 JUN 01.
9. C4, IN CONJUNCTION WITH THE DON CIO, WILL FACILITATE RAISING THE
LEVEL OF SECTION 508 AWARENESS THROUGH THE DISTRIBUTION OF TRAINING
MATERIALS TO PROVIDE POCS WITH GUIDANCE CONCERNING THE TWO MAJOR
AREAS IMPACTED BY THE LAW: WEB PAGE ACCESSIBILITY AND
EQUIPMENT/SOFTWARE ACCESSIBILITY. IN ADDITION TO TRAINING, THE POC
NETWORK WILL FACILITATE THE COORDINATION AND ATTAINMENT OF SECTION
508 COMPLIANCE ACROSS THE CHAIN OF COMMAND. LASTLY, THE PROGRAM
EXECUTIVE OFFICE FOR INFORMATION TECHNOLOGY (PEO-IT) IS WORKING WITH
EDS, THE NAVY MARINE CORPS INTRANET (NMCI) PRIME CONTRACTOR, TO MAKE
SOFTWARE/HARDWARE SOLUTIONS AVAILABLE UNDER THE NMCI CONTRACT.
10. A COMPLETE COPY OF THE SECTION 508 STANDARDS MAY BE FOUND AT
HTTP:DOUBLE SLASH WWW.ACCESS-BOARD.GOV/SEC508/508STANDARDS.PDF.
PROVIDE POC INFORMATION TO MAJ O'NEAL, DSN 223-3518/3490, COM
(703)693-3518/3490, EMAIL: ONEALMS@HQMC.USMC.MIL.//
BT