ISO Implementable Standards Robert Baker SSA Section 508 Coordinator For accessible transcript –- use notes pages exclusively. Title Slide contains picture of a man looking through binoculars Presentation Title: In Search of Implementable Standards Speaker: Robert Baker, SSA Section 508 Coordinator July Draft August Draft September Draft We started to the process of evaluating every page of the July Draft of the standards, followed shortly by the August draft of the standards, and followed just this past Friday by yet another September draft of the standards. And while we do not have detailed comments for you today on individual standards, we can draw some initial conclusions. So far... the fruit of TEITAC’s labor looks good! Picture of assorted fruits What we like: 1. Less ambiguity 2. More testable provisions 3. Better low vision support With each new draft of the standards, it is increasingly more apparent that there is less ambiguity, more testable provisions, and better support for low vision. Actually, I would like to recognize the hard work of all the individuals in this room representing industry, vendors, and advocacy groups for their efforts to modernize and improve the standards. I would also like to recognize the contribution of the Editorial Work Group to coordinate the multiple drafts in recent weeks. And finally, I would like to recognize my government colleagues, especially Al Hoffman and Terry Weaver, for their extensive commitment to this process. Where do we go from here? However, now that we are moving into closing the gaps of the few remaining unresolved standards, I am sure that manner of you are wondering -- How is this actually going to work? Industry wants achievable standards If you are a vendor or industry representative –- you probably are excited about the possibility of clear, testable, and possibly achievable standards. But you may also be wondering about how you are going to sell this to your technical and marketing teams back at the office. You might be wondering how you are going convince your management that conforming with the new standards will result in products that the federal government will buy, and that this will also help sales in the global marketplace. Some of you may even be wondering if these new standards will help your company turn 508 into a profit center –- as opposed to the cost center that it is for many firms today. Advocacy Groups want more accessible technology in government If you are representing an Advocacy Group, you are hoping to see more accessible technology in government as a result of the new standards. However, you too may be wondering how effectively the new standards will be implemented, and the likelihood that there be a material difference in accessibility as a result. Government agencies want more accessible product choices And speaking from the perspective of the federal government, we are thinking about of all of these things, not to mention being hopeful that the new standards will lead to more accessible product choices. Looks like the road ahead is clear So, for many of us –- the road ahead, which has been paved with the good intentions of everyone in this room, is beginning to look very promising. Basically –- we just need to wrap up a few items that are still outstanding and prepare for our final meeting and recommendation to the Access Board in January. But will the new 508 standards ...actually work for government? Picture of Caution Sign But before we break out the party hats -- I would like to add one word of caution. If 508 cannot be implemented by the federal government, we will not end up at the destination we expected. A formula for success? 508 standards + Conforming products + Federal mandate -- = More accessibility Back in 2001, the Access Board implemented what we thought was a formula for success 508 Standards Plus conforming products Plus a federal mandate Equals more accessibility It was thought that this formula would lead to more accessibility in the Government, and by extension more accessible technology available to the American public. 508 compliant purchases since 2001 Anticipated ???? Actual 2001 - 2007 However, since 2001 things has not turned out as expected. As you can see from this simple chart in 2001, we anticipated that the Government’s expenditure on accessible technology would gradually increase every year. What we have experienced is that while this has occurred, the rate of increase is less than what we have hoped for. Without having any specific numbers to back this, it should be intuitive that there is a gap between what has actually occurred and the original expectations, and the level of accessible technology actually in use in the federal government today. Simple Procurement Process 1. Define Need 2. Market Research 3. Obtain Proposals 4. Evaluate 5. Buy 508 has to work here [2, 3, 4]; To have an impact here [5]. To understand this problem, we need to take a step back and look at the procurement process, which is where Section 508 is implemented today. The five steps of the process are: Defining the business need Performing market research Obtaining vendor proposals And evaluating responses And selecting products Section 508 must be easy to implement during the market research, proposal, and evaluation stage in order to influence buy decisions. As we shall explore later in this presentation, Section 508 does not work well with any of these processes today. This needs to be addressed in the future. The average Procurement Official Is NOT a 508 Genius! Picture of Einstein The second factor we need to consider is “who is administering the procurement process?” Take for example the average procurement official (officially referred to as a Requiring Official). The average procurement official is not a 508 genius, or even a strong understanding of each of the provisions and why they are important. In fact, for those who have tried to take the time to understand the standards, many have ended up confused and frustrated. Adding to their frustration is the reality that most agencies are lucky to have one true technical 508 expert on staff, despite the fact that there many be hundreds of procurement contracts that must be administered each year. All this adds up to a mountain of paperwork, and every time more complexity and paperwork is added to the process, procurement officers become more frustrated. For 508 to succeed, we need to remove the obstacles blocking our way Picture of sheep blocking a car from traveling down a road For Section 508 to succeed, we need to remove the obstacles blocking the way. The primary remaining obstacle is complexity Picture of a twisting and winding road in a mountain vista The TEITAC Committee has made tremendous strides towards reducing the ambiguity of the standards and increasing their testability. These changes will help procurement officials who already have a good understanding of the Section 508 standards. However, for many, if not most, procurement officers, the new standards will be perceived as increasingly complex, While we have significantly reduced the level of complexity for technical individuals, we need to also consider how to reduce complexity for a procurement official. A new formula for success 508 standards + Conforming products + Federal mandate + Reduced Complexity -- = More accessibility A new formula for success is needed. Enhanced 508 standards plus Conforming products plus Federal mandate plus reduced complexity equals more accessibility Re-package 508 to reduce complexity 1. Understandable 2. Applicable 3. Actionable Picture of a wrapped package In order to reduce complexity for a procurement officials, we need to take a step back from the standards and look at how we can make them more Understandable Applicable and Actionable If we are successful, then it will be easier for procurement officials to properly account for Section 508 when they are: Performing market research Obtaining vendor proposals And evaluating responses And selecting products 1 [of 3] Understandable Part One: Understandable Standards Picture of a mini-cooper Consider for a moment the mini-cooper. Its small size, simplicity, and cute looks has this a very popular car in America and in Europe. From 67 to 87 standards From 12 to 41 definitions From 8 to 12 “categories” From 13 to 52 pages Is more always better? Picture of mini-cooper converted to a limousine. Now consider what happens someone takes this little car and converts it into a limousine. Now I need to ask you –- is more always better? Take a look at the new standards. Based on the August draft: We went from 67 to 87 standards From 12 to 24 definitions From 8 to 12 categories for grouping the standards And from 13 to 52 pages And that is without the metadata added in and with several new standards still to be defined Wait a minute Robert! We needed those changes to add clarity to the standards! Counterpoint Wait a minute Robert, we needed those changes to add clarity to the standards. Usability Recommendation Reduce or prioritize standards Picture of large stack of paper being to reduced to a small stack of paper The fact is that there are pluses and minuses to expanding the standards. However, what we must all remember is that unlike other accessibility standards such as WCAG –- 508 is not optional. Every standard that we have added or changed has the chance to become something that is mandated by the federal government once the changes are finalized through the rule making process. Therefore, we need to hold ourselves to a higher standard. My recommendation to the TEITAC board is that we should take a step back and ask –- is every standard we have added or changed absolutely essential? If we find that some standards fall into the “nice to have” category, where the guidance may be spot on but the impact or likely of occurrence is expected to be rare or infrequent, we should move these standards either to guidance or find some other way of denoting a lower priority. Perhaps the WCAG approach to multiple levels of priorities would be useful. Usability Recommendation Convey Importance to non-technical readers The second recommendation I have is to provide language in the standards that would help a non-technical reader understand the importance of an individual standard –- either in terms of the user experience or in terms of the risk of not conforming to the standard. Although the EWG group has done an admirable job applying plain English to the standards, they for the most part are best understood by a technical audience or one that is intimately familiar with assistive technology. Procurement Officials are a different audience. While some may increase their understanding of 508 as a result of reading the new standards –- the significance, or impact of conformance or non-conformance with the standards may be hard to discern without assistance. We could address this concern by adding a new metadata category titled “why is this important to a disabled user?” The provision of the information would be helpful to individuals trying to understand the standards. Usability Recommendation Usability Test everything! Picture of person in wheelchair strapped to a ramp, being usability tested for a restraint system that would allow a wheelchair to be bolted to an amusement park ride. My third and final recommendation is to perform usability testing. To be more specific, we should identify a representative sample of potential users of the standards, including Government of individuals who create statements of work, prepare solicitations, evaluate solicitations, and make purchase decisions, and Vendors who write technical requirements and prepare proposals for the government To be sure –- the standards will eventually be usability tested one way or the other. I am just proposing that we take this step before the standards are locked in stone –- verses afterwards. 2 [or 3] Applicable Part Two: Applicable Standards Is this 508? Picture of a Mini Cooper Once a year the federal coordinators get together and play a game called “Is it 508”? During our game –we are guess how 508 applies to certain products. Lets walk though an example. Going back to the Mini-Cooper... What if BMW came up with a feature that would allow the Mini-Cooper to drive itself? We already have cars that parallel park themselves –- can this be too far n the distant future? Should a blind person or a paraplegic be able to drive the car? Is it 508?” What about the GPS system that many cars already have. If I am blind or have low vision problems, should I be prevented from assisting the driver with navigation while I sit in the [passenger] seat? Is it 508? Is this 508? [Photograph of refrigerator with screen built into the door.] Lets take another example. LG now has a new line of refrigerators with smart sensors and visual displays. The refrigerators could be hooked up to a whole house computer network –and possibly even to applications that work through the Internet website at the local grocery store. Is this 508? What if the display could be used to display emergency information? What if the Department of Homeland Security provided the ability to display emergency information on the screen –- or provided a way to report an emergency situation such as a fire or a home intruder to the authorities. Is it 508? The problem with “Is it 508?” One Answer Many answers The problem with the “Is it 508” Game is that everybody comes up with a different answer. This plays out on a weekly basis on the 508 coordinators listserv, it has even played out when industry gave their presentation to the TEITAC Committee. There is a need to have a single source for this information that can be shared across government. Applicability Recommendation 508 Product Guide *includes applicable standards! Picture of a book. If we are really serious about implementing 508 –we need to get serious about providing guidance upfront to government agencies about which product types are subject to 508, and what standards are generally applicable to each product type. Depending on how extensive the metadata is for each standard –this information may already exist under the “product characteristics” and “product types” categories. We may need to look at this more carefully and determine if it will be extensive enough, and if it can be easily pulled out to provide a “508 Product Guide” for procurement officials. Which standards apply? VOIP Solution Picture of Voice Over I P Phone Taking this one step further, it is even more difficult for Procurement Officials to determine how to apply to standards to a complex procurement or solution. For example –take Voice Over IP. As Paul can attest, VOIP solutions consist of many integrated parts, products and services that can easily be provided by multiple vendors in response to an agency solicitation. Even a single product can be complex –such as the server example that Peter Korn provided us during the last industry presentation. Peter asked – when an agency assesses 508 conformance for a Sun Server, should it also assess 508 conformance for the operating system bundled with the server and any applications bundled with the operating systems? What if the operating system is going to be replaced by another operating system of the agencies own choosing –- how should 508 conformance be evaluated? Once again –we run into the “one or many answers” problem –- and the potential for lack of consistency across the federal government for the similar solutions. Applicability Recommendation Create applicability guidelines for complex products and solutions The major questions are: How should 508 be evaluated when multiple products are bundled together into a solution? How should 508 be evaluated when all the features will not be implemented? Therefore, I would like to recommend that the US Access Board provide general guidelines that can be used to determine how 508 applies when a “product” actually consist of a solution containing multiple products. I would also like to suggest that the US Access Board consider developing guidelines for defining applicability of the standards to product features that will not be implemented by the government. 3 [of 3] Actionable We have already mentioned that the key area to focus on to improve the implementation of 508 is the market research, proposal, and evaluation stages of the procurement process. It should be fairly clear to everyone that if at the end of all our hard work, a procurement official is not able to determine which product or solution is more “508 compliant” than another –- all of our work essentially goes to waste. Unfortunately –- this is one of the biggest flaws of Section 508. Essentially, there is only limited central guidance available to help Procurement Officials compare two products which are not fully compliant. With more standards, it is more likely that more products will not be fully compliant, so the problem is going to get compounded when we release the new standards. This situation has and will lead to a lot of confusion amongst vendors and government agencies. 508 needs to be actionable. Procurement Officials need to be able to use 508 to pick the most compliant product that meets their business need. Actionable Recommendation Create a new Government Product Accessibility Template The current VPAT is cumbersome and does not make it easy for a procurement official to compare two products side by side. While re-formatting and clearer directions could be helpful, one of the weakest areas of the VPAT is the summary. We need a way to gather product information using a method that is scalable and enables clear product comparisons. Key GPAT Features 1. More clarity for “fully supports” and “partially supports” 2. Supporting documentation & validation methods 3. Numeric Counts To be more at effective at helping Procurement Officials to compare products, the following areas need to be addressed. More clarity for “fully supports” and “partially supports”. Supporting documentation & validation methods. Numeric Counts. Government Product Accessibility Template Product / Solution Name Applicable Product Types Applicable Product Characteristics Validation Methods Applicable Standards _%_ Fully Supported _%_ Partially Supported _%_ Not Supported Supporting Documentation & Explanations Here is an example of the information that a sample GPAT Summary Page could contain: Applicable Product Types Applicable Product Characteristics % applicable provisions fully supported % applicable provisions partially supported % applicable provisions not supported Validation Methods Supporting Documentation & Explanations [Lane Drop Ahead] Picture of half finished bridge If we do not focus on implementation issues, will run the risk of creating a new set of standards that may be even harder for government agencies to use than the current set of standards. A new formula for success Enhanced 508 standards + Conforming products + Federal mandate + Reduced Complexity -- = More accessibility The answer lies in maintaining the improvements already made with the standards But also in recognizing that we must reduce the complexity of the standards if we are to realize our hopes and plans for more accessible technology in the federal government Re-package 508 to reduce complexity 1. Understandable 2. Applicable 3. Actionable Today, we have identified three key themes that can be used to identify ways to re-package the standards to reduce complexity for federal procurement officers. For procurement officers to effectively implement Section 508, the new standards must be understandable, applicable, and actionable. Re-package 508 to reduce complexity Understandable * Reduce or prioritize standards * Convey importance to non-technical reader * Usability test everything Applicable * Create a pre-defined “508 Product Guide” that defines which standards apply to each product type * Create applicability guidelines for complex products and solutions Actionable * Create a new GPAT to address the revised standards We have also explored several ideas for reducing complexity under each theme. We explored how we could make the standards more understandable by: Reducing the volume of standards to essential items or adding a prioritization scheme. Conveying the importance of the standard to a non-technical reader through additional metadata. Usability testing everything the standards, guidance, and templates to validate usability with key stakeholders We explored how we could make the standards more applicable by: Creating a pre-defined “508 Product Guide” that defines which standards apply to each product type. Creating applicability guidelines for complex products and solutions We explored how we could make the standards more actionable by: Creating a new GPAT to address the new standards Build flexibility For now For the future Picture of acrobat contortionist If we balance our efforts on creating a technical standard that is usable by both the technical community and the government procurement community, we will surely be building a structure that will be flexible for now and for the future. Revised standards + Collaboration + Focus on implementation -- = WOW!!! Picture of hands clapping In closing –- I would like to suggest a new formula for success: Revised standards Plus collaboration Plus focus on implementation Equals a new 508 that we can be proud of “They are able who think they are able” Virgil, Roman Poet Thank you for your time.