| Home |
 |
This chapter describes the Postal Service roles and responsibilities related to complying with Section 508 legal requirements.
As designated by the Postmaster General, The Vice President/Chief Technology Officer (VP/CTO) leads the Postal Service Section 508 effort. The VP/CTO does the following:
a. Establishes a Postal Service information technology infrastructure that both responds to corporate business needs and enables compliance with requirements related to Section 508.
b. Provides Postal Service technology and development standards for the design, development, use, and maintenance of Section 508 compliant information technology systems.
c. Identifies and assigns the organizational roles and responsibilities necessary to ensure Postal Service compliance with Section 508.
d. Designates a Section 508 Program Manager to lead the corporate-wide Section 508 initiative.
The Section 508 Program Manager, as designated by the VP/CTO, does the following:
a. Coordinates overall activities undertaken by the Postal Service in guiding our response to Section 508.
b. Develops and disseminates Postal Service policies, procedures and requirements, related to achieving implementation of, compliance with, and institutionalization of Section 508.
c. Provides high-level technical guidance on the Electronic Information Technology (EIT) accessibility standards.
d. Identifies functional organization stewardships that correspond to the following Section 508 technical specification standards in the following products and services areas:
(1) Software applications and operating systems.
(2) Web-based intranet and Internet information and applications.
(3) Telecommunications.
(4) Video and multimedia.
(5) Self-contained, closed products.
(6) Desktop and portable computers.
e. Identifies functional organization stewardships that correspond to the non-technical specifications of the law and standards for the following areas:
(1) Purchasing.
(2) Consumer complaints.
(3) Employee complaints.
(4) Legal guidance.
f. Prepares and provides the Postal Service's input to the U.S. Department of Justice for inclusion in the Attorney General's biennial government-wide accessibility report to the President. Prepares other reports as required by the Department of Justice.
g. Identifies an agency Section 508 coordinator and backup coordinator and provides this information to the Architectural and Transportation Barriers Compliance Board (hereafter, "Access Board") and General Services Administration (GSA) Section 508 Interagency Program.
h. Serves as the Postal Service liaison to the Access Board and GSA Interagency Program.
i. Directs the Section 508 Program Team by doing the following:
(1) Managing the day-to-day program activities.
(2) Addressing the varying demands of the program.
(3) Establishing program objectives.
(4) Facilitating coordination of stewardships across the Postal Service in the following areas:
(a) Standards definitions and integration.
(b) Evaluation processes.
(c) Training for all audiences.
(5) Providing a framework for communication vehicles: handbook, brochures, videos.
(6) Creating and conducting education and awareness throughout the agency.
(7) Reporting program status to senior management.
j. Coordinates and implements processes resulting in the institutionalization of Section 508.
The VP/CTO designates a Technical Steward for each of the six EIT accessibility standards. (see http://cto.usps.gov, click on Support, Standards & Guidelines, 508 Standards and Support). Technical Stewards and their associated EIT technical standards are listed in exhibit 2-3. Technical Stewards do the following for their respective EIT standard(s):
a. Serve as the Postal Service technical experts.
b. Provide technical guidance and support for the content of Postal Service Section 508 policy and technical documents to enable the Postal Service to comply with Section 508 when purchasing or developing EIT.
c. Provide technical guidance and support to Postal organizations on their specific Section 508 standards.
d. Establish testing and evaluation benchmarks that are in harmony with the generic testing approaches and techniques defined in this handbook.
e. Stay abreast of changes to the technical standards and update Postal Service Section 508 policy and technical documents accordingly.
f. Help functional organizations respond to inquiries and complaints concerning the class of technology for which they are the stewards.
g. Create and conduct training on the technical area of their stewardship.
h. Coordinate among stewardships to ensure that interpretations rendered by stewards are consistent, and to address issues that arise when EIT solutions are covered by more than one Section 508 standard.
i. Promote ongoing communications and education within the Postal Service.
j. Represent the Postal Service on interagency working groups to further understanding and consistency of technical guidance.
Exhibit 2-3
| Steward | Section 508 EIT Technical Standard |
|---|---|
| Mgr., Business Solutions Services, IT | • Software applications and operating systems. |
| Mgr., Telecommunications., IT | •
Telecommunications products. (Includes telephony interactive voice response systems, data, and other telecommunications equipment and services.) |
| Mgr., Enabler Business Systems Portfolio | • Video and
multimedia products. (Includes related training and promotional materials.) |
| Mgr., Technology Support, IT | •
Self-contained and closed products. (Includes kiosks, copiers, printers, calculators, mail processing equipment, scanners, fax machines, point-of-sale terminals, etc.) |
| Mgr. Distributed Computing Environment, IT | • Desktop
and portable computers. (Includes employee workstations and laptops.) |
| Mgr., Corporate Business Systems Solutions | • Web-based intranet and internet information and applications. |
The IT Portfolio Managers do the following:
a. Acquire an in-depth knowledge of Section 508 requirements.
b. Disseminate Section 508 knowledge for their area.
c. Champion Section 508 compliance of their area.
d. Determine how Section 508 applies to each new business function.
e. Ensure that market research and other Integrated Systems Methodology (ISM) procedures include Section 508 considerations within the EIT life cycle.
f. Document Section 508 compliance within their area of responsibility, including updates to the Enterprise Information Repository (EIR), Infrastructure Tool Kit (ITK), or other databases as needed.
g. Assist Functional Organizations to document exceptions when a solution is not completely Section 508 compliant.
The Vice President, Labor Relations (LR), does the following:
a. Provides policies and procedures on the Section 508 employee complaint process and any other labor-related areas affected by Section 508.
b. Integrates Section 508 policies and procedures into existing labor-relations processes and documents.
c. Creates and conducts training to affected parties to promote awareness.
The Vice President, Supply Management, does the following:
a. Provides policies and procedures on how the Postal Service purchases any products that involve compliance with Section 508 requirements.
(1) Creates and incorporates applicable procurement clauses into the Purchasing Manual.
(2) Creates and implements processes to insure that the Postal Service follows the legal requirements for complying with exceptions and undue burden documentation.
b. Integrates policies and procedures of Section 508 into the existing Supply Management processes and documents.
c. Creates and conducts training for contracting officers and others involved in the purchasing process.
The Vice President, General Counsel (GC), does the following:
a. Updates legal publications and Postal Service policies and procedures in the GC area to conform with ongoing legal requirements.
b. Provides legal guidance in response to Section 508-related inquiries from functional organizations and the Section 508 Program.
c. Notifies affected functional organizations of updates to relevant statutes and related interpretations.
The Vice President, Consumer Affairs (CA), does the following:
a. Provides policies and procedures on processing consumer complaints.
b. Integrates policies and procedures concerning Section 508 into the existing processes and documents.
c. In consultation with the General Counsel, updates 39 CFR 255 and any Postal Service CA policies that are affected by Section 508.
d. Manages the response of consumer complaints.
The Vice President, Public Affairs and Communications, designates the manager of USPS TV to be responsible for the multimedia stewardship.
All Postal Service officers do the following:
a. Designate a liaison to coordinate Section 508 activities within and among their respective organizations.
b. Champion Section 508 compliance within their organizations.
c. Fund the cost of compliance and litigation for their organizations.
d. Authorize exception or undue burden documents for the requiring functional organization, if a solution is not completely Section 508 compliant (see section 4-6).
Functional organizations have the responsibility and legal liability for Section 508 compliance. This ensures all products, including those a contractor develops or supplies in accordance with contract requirements, comply with Section 508. Contracts should include requirements for contractors to comply and may include contractor responsibility for testing, but acceptance of a product or service as compliant is the legal responsibility of the Postal Service.
All functional organizations that require EIT do the following:
a. Follow the requirements of the law and of this handbook when they use, develop, procure, or maintain EIT products and services.
b. Respond to Section 508 inquiries or complaints from the public according to 39 CFR 255, Access of Persons with Disabilities, regarding EIT controlled by their functional organizations.
c. Respond to Section 508 inquiries or complaints from employees following established procedures.
d. Provide information on the status of Section 508 EIT compliance as required.
e. Create exception or undue burden documents for approval of their respective vice president when a solution is not completely Section 508 compliant (see section 4-6 of this handbook).
Section 508 stewards, as designated by their Postal Service officer, do the following:
a. Acquire an in-depth knowledge of Section 508 requirements.
b. Coordinate Section 508 activities within their respective organizations.
c. Respond to reporting requirements on Section 508 compliance within their respective organizations.
d. Stay abreast of changes to the Section 508 program.
e. Develop an ongoing education/information awareness activity to make sure employees within their organization are aware of Section 508 program updates.
Compliance with Section 508 requirements does the following:
a. Demonstrates our commitment to implementing business practices that make our IT-based products and services accessible to our employees and customers with disabilities.
b. Reinforces the worldwide reputation of the Postal Service as a trusted provider of communications - for all people.
c. Enhances business opportunities.
d. Avoids costly litigation.
e. Improves the overall visability of our information resources.
For all phases of the EIT life cycle, compliance monitoring resides with the responsible functional organization. The functional organizations have this responsibility for all EIT purchased or developed by the Postal Service.