HHS Section 508 FAQ's
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Last document update: July 31, 2007
508 Basics
Q: What
does Section 508 Cover?
A: Almost
everything electronic, from a fax machine to a sophisticated
payroll management system. There are exceptions,
but all EIT is processed using OPDIV 508 procedures
and any determined exceptions documented.
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Q: What
is the purpose of Section 508?
A: Section
508 states that when Federal agencies develop, procure,
maintain, or use electronic and information technology
(EIT), Federal employees with disabilities shall have
access to and use of information and data that is comparable
to the access and use by Federal employees who are
not individuals with disabilities, unless compliance
would impose an undue burden on the agency. It also
includes individuals with disabilities, who are members
of the public seeking information or services from
a Federal agency have access to and use of information
and data that is comparable to that is provided to
the public who are not individuals with disabilities,
unless compliance would impose an undue burden on the
agency.
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Q: Is
there a Section 508 Complaint Process?
A: The
Section 508 legislation passed in 1998 included enforceable
and binding provisions that hold Federal agencies accountable
when they procure EIT. The law places legal responsibility
on the Federal agency to ensure that EIT purchases
are accessible to persons with disabilities. Persons
with disabilities (Federal employees and members of
the public) can file civil action against the Federal
agency that fail to purchase accessible EIT products
and services. The civil action is filed against the
Federal agency and not against an individual such as
a web developer or requiring official. For true internally
developed EIT, Federal employees should follow the
administrative complaint procedures as stated in Section
504 of the Rehabilitation Act of 1973. See: Speak
Out! - ITTATC
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Q: Our
office does not employ any employees with disabilities.
Would that make us exempt from complying with Section
508?
A: The number
of people with disabilities is not relevant.
If we procure, maintain, develop or use electronic
and information technology, it must conform to the
applicable provisions of the 508 standard.
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Q: What
is Electronic and Information Technology?
A: Electronic
and Information Technology (EIT) are software and hardware
products that people use everyday to obtain and retrieve
information electronically. EIT includes computers
(i.e., desktop and laptop), photocopy machines, fax
machines, software applications (Word), operating systems
(i.e., Windows), web sites and web pages, and telecommunication
products (i.e., telephones and TTY's).
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Q: What
does Comparable Access mean?
A: The
intent of Section 508 is to ensure that Federal employees
and members of the public have the ability to access
the EIT information and data that is similar to the
information and data that persons without disabilities
have. The Section 508 requirements where created to
guide Federal agencies in ensuring comparable access
is provided. This does not require changing the format
or the method of delivery of the information and data.
Instead, the focus of 508 is to affect the way in which
EIT is created so that the end product is accessible
to persons using assistive technology.
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Q: What
is the difference between accessibility and accommodation?
A: Accessibility
is an approach to creating an environment that allows
people to access the environment. An example includes
building an office with a wheelchair ramp to allow
persons using a wheelchair the ability to move around
freely within the workplace. Accommodation is
modifying or adding a device to a workplace that allows
a person the ability to work. An example includes
the use of screen reader software by a person with
blindness to read information from their computer.
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Q: What
is the difference between alternative access and
equivalent facilitation?
A: Alternative access
methods address the need to provide alternative ways to deliver
information to a user in the event that a product is inaccessible
as a result of an undue burden. Equivalent facilitation addresses
the procurement of products that grant equal
or greater accessibility even if they do not meet the specific
provisions of the Section 508 standards.
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Q:What
is the difference between Section 501, Section 504 and
Section 508 of the Rehabilitation Act?
A:
Q: I
need more information. Where can I get it?
A: There
are several sources. Start at the HHS Office
on Disability web site. Then check out the information
and FAQ at www.section508.gov. For
technical questions on the standards, check out the
Access Board at www.access-board.gov.
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Internet / Intranet and
Documents
Q: How
is it determined if software or a web site conforms
to the provisions of Section 508?
A: To
determine if software or a web site conforms to the
provisions of Section 508, use a test script, manual
testing, automated testing, or checklists to
evaluate internally developed and/or procured web or
software applications. Information regarding
the standards can be found at GSA's Section 508 web
site. under “About 508”. This section details
the various requirements used in determining Section
508 compliance.
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Q: Do
HHS videos and multimedia products need to be captioned
or audio described?
A: The video
and multimedia technical provisions (c) and (d) pertain
specifically to HHS videos and multimedia products.
They state that all training or informational
video and multimedia productions, which
support the agency’s mission, must be captioned
for persons who are hard of hearing or deaf and audio
described for persons who are blind or low vision.
Also, if the informational video or multimedia production
has audio or visual information that is necessary to
comprehend the content, then they must be captioned
or audio described. For example, CDC produced a videotape
to convey its mission. The video was captioned (words
appear on the screen) so that persons who are deaf
or hard of hearing can see the content of the video.
The tape also provided audio description (spoken words)
so that persons who were blind or low vision could
listen to the content.
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Q: Do
online Word documents and PowerPoint presentations
need to meet the Section 508 web standards and
provisions?
A: Yes,
any Word document or PowerPoint presentation that is going to
be placed onto the Intranet or Internet needs to meet the applicable
technical web provisions. The developer needs to look
at the 16
web provisions and determine which of those provisions applies
to the Word document or PowerPoint presentation. The developer
will need to then follow the technical specifications in the
applicable provisions to make the Word document or PowerPoint
presentation accessible. For example, if the Word document
contains images or graphics, then the images or graphics will
need to have text descriptions provided describing their meaning.
If a PowerPoint presentation contains images or graphics then
those images or graphics will also need text descriptions provided
describing their meaning. The intent is to make all documents,
no matter their format, that will be placed on the Intranet
or Internet compliant with the applicable web provisions.
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Q: Does
Section 508 apply to print documents?
A: No,
unless the print document is support documentation for a software
program or a description of accessibility features of EIT – in
which case an alternative, accessible format must be available. Otherwise,
the requirements of Section 508 only apply to the use, development,
maintenance or procurement of EIT products. If a document is
going to be placed onto a Federal agency web site, then the
content must comply with the applicable web-based technical
provisions.
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Q: How
do web developers create web pages that are accessible
for individuals who are color blind?
A: The
most common form of color blindness is red-green (the
inability to distinguish between the color red and
green). There is a wide range of variability within
this group ranging from mild to extreme. The second
most common form is blue-yellow, and a red-green deficit
is almost always associated with this form. The colors
blue, yellow, green and red are commonly used on Internet
and Intranet web pages. It is the contrast of the colors
that affect how individuals who are color blind view
the web page. Color and Contrast Techniques
- Avoid using similar color combinations in the interface and
graphics. Specifically, avoid using yellow/blue/red/green/brown/gray/purple
next to, on top of, changing to yellow/blue/red/green/brown/gray/purple.
It is how these colors are used, particularly if they are used
against each other that result in problems.
- Use background patterns and colors that contrast
well with lettering. Dark type and graphics against
light, plain backgrounds are easiest to read and
see.
- Avoid using colors by themselves to convey meaning
or give directions to users.
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Q: Do
automated web testing tools find and repair all 508-web
compliance errors?
A: No.
While some automated web-testing tools on the market
have the capability to find and repair web 508 compliance
errors, none can find and repair all errors through
a strictly automated process. There are web testing
and repair tools that are free and available for download
from the Internet. There are other web testing and
repair tools that can only be purchased by a product
vendor. AccMonitor (HiSoftware), which is available
via MITS Web Services, is an automated web-testing
tool that will find web compliance errors but will
not repair them. The tool will test a web site for
Section 508 web accessibility errors and will generate
a report, which details the files that have failed.
An accessibility checklist is also generated so the
developer can see which of the 16
web provisions the web site failed to meet. AccMonitor
will test the web site and generate accessibility and
compliance reports but it is up to the web developer
to code the changes required in order to meet each
of the applicable web provisions.
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Q: Can
Excel Spreadsheets or PowerPoint Presentations be
put as files on a web site?
A: Some
Federal agency’s internal testing has determined
that the free viewer programs for these types of files
may not meet all of the Section 508 software criteria. Therefore,
files of these types deployed via the Internet should
be converted to HTML, and then reviewed to ensure their
compliance with the 508 standards for Web-based Internet
and Intranet documents. If placing Excel or PowerPoint
(.ppt or .xls files) documents on an INTRANET site
in original form is absolutely necessary – for
example a group template, then it the responsibility
of the author and the business unit manager to ensure
that all persons needing access to the file have full
working versions of the application, not just the viewers.
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Q: Can
I test my web site. with an automated tool and
get my 508 status?
A: Yes and
no.Yes, automated tools can check for some of the provisions
for web, and no they can not check for all of the provisions
for web.To illustrate this point, let's consider automated spell
checkers in word processing programs as an analogy. The spell
checker can find words that are not in its dictionary, and even
suggest replacements, but cannot identify a correctly spelled
word used incorrectly. For example, if I type, "Did
you loose you keys?" when I meant to write, "Did you
lose your keys?", the automated spell checker will not
detect this error. Similarly, while all accessibility checkers
will identify missing "alt" text on images and other
Web elements, none can check if the Alt text is "equivalent," as
required by the guidelines.
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Q: How
should I communicate the fact that my web site or
software application is accessible?
A: When
communicating to the agency or members of the public
about the accessibility of HHS products it is important
to first talk about "people, or members of the
public with disabilities", not one specific disability
such as blindness. It is also important to talk about
assistive technologies in general, not specific
products like JAWS. Lastly, rather than saying
that your product is accessible, you should be able
to communicate that the product was developed to conform
with the provisions of the Section 508 amendments to
the Rehabilitation Act of 1973 and will provide individuals
with disabilities, who may use assistive technology,
equal access to and use of your product as provided
to those without disabilities.
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Acquisitions
Q: Must
EIT products meet all of the Section 508 technical
provisions?
A: Part
of the Federal requiring officials’ responsibility
in procuring an EIT product that is 508 compliant,
is deciding which of the six categories of technical
provisions applies to the EIT product. For example,
if the Federal requiring official is looking to purchase
a copier, then he or she needs to look at which of
the six categories of technical provisions is applicable
to the purchase of a copier. After the Federal requiring
official becomes familiar with the differences between
each of the six categories, he or she will know that
the Self-Contained, Closed Products provisions apply
to the purchase of a copier. These are the only provisions
out of the six categories that apply to the purchase
of a copier. Next, the Federal requiring official wants
to buy a software application like the newest version
of Word, and then he or she will determine that only
the software applications and operating systems provisions
apply. Now, if the Federal requiring official is looking
for a more complex EIT product purchase like a web-based,
software application that allows managers to monitor
the customer calls that come into the call centers
then he or she will need to look at multiple technical
provisions to determine which apply. Most likely the
software applications and operating systems, and the
web-based information and applications technical provisions
will both apply to the purchase of this EIT product.
The software application will need to be accessible
to users of assistive technology while interacting
with the application on the Intranet, and the control
functions and operating features will also need to
be accessible to someone using a keyboard or the built-in
accessibility functions of the Windows operating system.
As previously stated, the determination of which of
the six categories of technical provisions applies
to an EIT procurement will depend on the functionality
and intent of the EIT product. It will also depend
on the requiring official’s understanding of
each of the six categories of technical provisions.
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Q: Does
Section 508 require the provision of alternative
formats?
A: Yes,
alternative formats of procured EIT product information,
product instructions and user guides must be made available
at no additional charge and only upon request. Alternate
formats or methods of communication, can include Braille,
cassette recordings, large print, electronic text,
Internet postings, TTY access, and captioning and audio
description for video materials. The EIT product materials
are provided in an alternative format so that they
meet the individual needs of the person with a disability.
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Q: How
do I determine which standards apply?
A: If
you are having trouble determining applicable provisions,
GSA is introducing a tool called the “Section
508 Wizard” which will walk you through the process. The
Access Board web site. at www.access-board.gov also
has excellent information, and can provide technical
assistance with questions on the standards.
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Q. Does
this mean I have to test every piece of EIT I buy?
A: Testing
should be done by the vendor,
reported via the VPAT and
verified by the OPDIV (or OS) as meeting their needs. Acceptance
is a process of verification and awareness of any accessibility
concerns, NOT setting up a Lab to ensure every disability
can gain comparable access. This is a requirements
review process (again for risk management and compliance
purposes) - not a detailed technical evaluation. A "determination
and finding" will be made by the OPDIV that, based
upon the information gathered, the product procured
either meets all applicable 508 provisions, or it fails
in identified provisions but is the most accessible
product available.
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Q: How
does Section 508 Apply to Information, Documentation
and Support?
A: When
an EIT product is procured by a Federal agency, persons
with disabilities need access to the information about
the product, product instructions and user guides in
a format that is usable and accessible. Section 508
also requires that persons with disabilities be provided
with functionally equivalent access to support services.
Support services include technical support hotlines
and databases; call centers, service centers, access
to repair services and billing services. For example,
agencies acquiring help desk technical support must
ensure that assistors are capable of accommodating
the communication needs of persons with disabilities
(communicate using a TTY).
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Q: How
is assistive technology defined in terms of Section
508?
A: Assistive
technology, as defined in 36 CFR 1194.4, is any item,
piece of equipment, or system that has been either
customized, obtained commercially, or modified and
is commonly used to enhance, maintain, or improve
functional capabilities of people with disabilities. The
intent of Section 508 is that EIT be compatible with
assistive technology. In some cases, however, the
technical provisions may require that EIT be readily
usable without the need for assistive devices. For
example, multimedia products that require captioning
and descriptive video, must have these elements built
in up front, as it is impractical to expect the user
to add on these features.
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Q: How
is Functional Performance Criteria Determined?
A: If there were
no applicable technical provisions identified from Subpart B for
an EIT product being procured, then the functional performance
criteria provision, Subpart C would need to be applied. The functional
performance criteria involve evaluating the overall product functionality
and performance to ensure individual accessible components work
together to create an accessible product. These provisions are
structured to allow persons with sensory or physical disabilities
to locate, identify, and operate input, to control mechanical
functions, and to access to the information provided including
text, icons, labels or operating cues. The intent is to ensure
the EIT product is accessible for persons with disabilities on
its own without requiring the use of assistive technology to make
the product accessible. The EIT being procured must function in
a method of operation and information retrieval that does not
rely solely on any one of the following user abilities:
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