Section 508 Cookbook
How to Create a
Section 508 Program From Scratch
1
Section 508 Cookbook
Recipes for
Creating a Section 508 Program
2
Ingredients – Agency Support
Discuss with upper management their:
• Expectations of a program and goals
• Level of support they will provide
• Concept of your role and responsibilities
• Resources ($$ and personnel)
Tip: Know what they will really do versus what
they say they will do
3
Ingredients – 508 Coordinator
Characteristics of a Coordinator
• Has authority base (either grade or management
support) to be able to make decisions, take
action, and enforce process and policy
• Understand the organization’s policies and
constraints (e.g., funds)
• Have admin or program management skills.
Tech support should be available as needed
4
Ingredients – 508 Coordinator
Characteristics of a Coordinator
• Solution/customer oriented. Strive for win-win
situations.
• Working relationship with:
• Office of General Counsel (OGC)
• Office of Procurement
• Office of CIO
• Believes in Section 504 and 508
• Understands/involved with Section 504
5
Ingredients – 508 Coordinator
Why understand and be involved with
Section 508?
• Only way to truly understand 508
• Grievance process for 508 should overlay 504
• Many 508 issues overlay 504 (design to 508 and
have 504 make it usable to employees)
• There are infinitely more legal action against
504 than 508
6
Ingredients – 508 Coordinator
Why understand and be involved with
Section 508?
• 504 can result in $300K compensatory
damages.
• While 508 may not be funded, 504 must be.
• Many 508 claimed programs are actually 504.
Need to know the difference.
• Efforts with 504 helps resolve 508 employee
problems before they become a grievance
7
Ingredients – Team Members
Team member characteristics
• Good grasp of their area’s processes, procedures
and policies
• Can speak for their management
• If necessary, can make decisions
• Has experience or represents their area in either
procurement, Section 504 and/or IT issues
8
Ingredients – Team Members
Team members should represent
• Cost centers or major areas in agency
• OP
• OGC
• Area responsible for Electronic procurement
9
Ingredients – Team Members
Team Members should represent
Office of CIO
• Web services
• Software development
• Acquisition management
• Testing and evaluation
• Section 504 IT coordinator
10
Mixing – Current Process
• Flow chart each area’s procurement/
development process from conception to
implementation.
• Identify critical areas and problems
• Identify areas that are similar, unique, and/or can
be changed
• Identify roles and responsibilities throughout the
process
• Develop a standardized process that will work in
each area.
11
Mixing – Current Process
• Develop standardized roles and responsibilities
• Determine how 508 compliance will be
determined, monitored, and enforced.
• Determine checks-and-balances in process to
ensure compliance.
• Get team buy-in
12
Mixing - Proposed Process
Tips:
• Keep as close to the current process as possible
• Have process flexible so areas can “personalize”
for unique requirement
• Each team member should have vested interest in
process (e.g., make them local 508 coordinators)
13
Mixing - Proposed Process
Based the proposed process on:
Awareness.
Responsibility.
Enforcement.
14
Mixing - Proposed Process
Awareness
• Inform employees, contractors, and vendors of
the program
• Concentrate on individuals who have a role/
responsibility in the program
• Create an easily accessible intranet site that
outlines the process and includes the standards
and checklists
15
Mixing - Proposed Process
Awareness
Intranet site should include:
• Outlines the process
• Includes standards as written in law
• Includes plain English version of standards
• Standards written as questions so they can be
used to determine status of compliance
• Includes supporting docs (e.g., checklist)
16
Mixing - Proposed Process
Responsibilities
USPTO checklist for Procurements
17
Mixing - Proposed Process
EIT Procurement Checklist
for Section 508 Compliance
Requisitioner Requisition Number 1
Program Office EIT Coordinator Review
Product Description
Check all
Pre-Award Action for EIT Procurements appropriate
for information on completing this checklist, see Instructions or your EIT Coordinator boxes
Exemptions to Section 508
Back-Office (Mostly includes data centers and comm closets type-equipment)
Fundamental Alteration (for example, cell phones, PDAs, pagers, hand-held devices)
Service and maintenance agreements (only for technical-type support)
Subparts and Categories for Section 508 Compliance
Subpart B - Technical categories of standards (procurement may include more than one)
Software applications and operating systems (36 CFR part 1194.21)
Web-based internet and intranet information and application (36 CFR part 1194.22)
Telecommunication products (36 CFR part 1194.23)
Video and multi-media products (36 CFR part 1194.24)
Self-contained, closed products (36 CFR part 1194.25
Desktop and portable computers (36 CFR part 1194.26)
Subpart C - Functional performance criteria (only when Subpart B does not apply)
Subpart D - Information, documentation, and support documentation requirements
Initial
appropriate
Market Analysis for Section 508 Compliance boxes
Products available, but they do not meet any of the appropriate standards
Product(s) compliant (i.e., previously approved as compliant or on desktop computer contract)
Limited product availability (one product meet more 508 standards than others) (attach analysis)
Only one product meets functional specifications (attach justification)
Note: For an EIT procurement to be awarded, it must have a completed and attached procurement and vendor checklist. This
includes sole source procurements. Exempt products only require a procurement checklist.
Requisitioner Date
Technical Date
Signatures required to certify accuracy and completeness of the checklist and Section 508 compliance.
18
Mixing - Proposed Process
Responsibilities
Lessons-learned on Procurement
Checklist
• Only 508 coordinator approves exceptions
• Keeps coordinator in the loop on problems
• Reinforce who coordinator is
• Precludes abuse of exceptions
19
Mixing - Proposed Process
Responsibilities
Lessons-learned
• 508 only initials checklist
• Two types of maintenance
• Updates of form for lessons learned
• Sole source
• Previously
• Emphasize that buyer is legally responsible
20
Mixing - Proposed Process
Responsibilities
Lessons-learned
Have buyer sign and certify 508 compliance
Project Manager: _____________________ Date:_____
Signature required to certify accuracy and completeness of checklist and Section
508 compliance
21
Mixing - Proposed Process
Responsibilities
Tips
Importance of having buyer sign document
• Some has assumed in writing responsibility for
compliance
• Most people unwilling to break law after they
certified
• Strong argument for people willing to ignore law
22
Mixing - Proposed Process
Responsibilities
Lessons learned on Market Research/Vendor
Checklist
• Use of “and how” have proven very effective
• Vendors can not compete for contract until they
have completed the checklist and are proven to
be compliant.
• Even sole source procurements require checklist.
• Completed checklist is official part of
procurement process
23
Mixing - Proposed Process
Enforcement
• Products can not be accepted without signed
checklist
• Vendors not considered w/o checklist
• SW can not be deployed w/508 deficiencies
• Contractors resolve deficiencies at their own
expense
• Non-compliant web pages pulled from
• Inter/intranet
24
Mixing - Proposed Process
Finalizing Process
• Draft documents, checklists and
instructions for processing products
• Have team members review
• Develop plan and schedule to implement
process
25
Mixing - Proposed Process
Finalizing Process
Have the plan and process reviewed and approved
by:
• Management
• OP
• OGC
• Other appropriate areas (e.g., OCR, OCIO)
26
Mixing - Proposed Process
Finalizing Process
Implement process
• Develop training packages for employees,
contractors and vendors
• Schedule training and implementation date
27
Mixing - Proposed Process
Finalizing Process
Promote process
• Team members promote in their areas
• Use agency-wide announcement system
• Train…and train again…and again
• Promote positive points of program
• Ensure 508 is part of budget, development,
procurement, deployment and web discussions
28
Mixing – General Tips
Establish an accessibility tool (AT) baseline
• Allows for more effective and efficient use and
maintenance of AT
• Less AT interface problems
• Creates more standardized and easier to
implement accommodations
• Simplifies accessibility with each new AT
revision
• Simplifies training requirements and
documentation
29
Mixing – General Tips
Know the law:
• Only way you can develop legal solutions to
problems. Be part of the solution and not the
problem with 508 issues.
• You are your agency’s expert and incorrect info
can have major impact on people and money
• When confronted when unique exemptions, make
sure you totally understand requirement
• Questions on interpretation, call fellow
coordinators, working group or Access Board
30
Mixing – General Tips
Exceptions and Disclaimers
• Establish well-defined standards for exemptions
and disclaimers. Avoid exceptions to the
standards
• Define “back office.” Often challenged
• Very limited use of disclaimers. Easily overused
and abused.
• Monitor web sites and training modules for
disclaimers
31
Mixing – General Tips
Team Members
• Ensure each everyone feels like they have
contributed to the process
• Have all team members’ buy-in
• Make them part of process and give them
responsibilities
• Officially recognize them for their role
32
Baking –Product Procurement
Certification: Individual buying the product signs
checklist to certify that the product is compliant
Responsibilities. Person buying the product:
• Performs all 508 requirements (e.g., market
survey, vendor checklist)
• Completes the checklist and certifies compliance
• Obtains the EIT Coordinator’s initials on the
checklist
33
Baking –Product Procurement
Process. Person buying the product:
• Determines functional requirements
• Conducts market survey on vendors who meets
functional requirements
• Has vendors who meet functional requirements
complete 508 standards checklist
• Determines which vendor meets the most 508
standards
34
Baking –Product Procurement
Process. Person buying the product:
• Completes 508 Procurement checklist and
include appropriate documentation (e.g., sole
source justification, vendor checklists, market
survey results, requisitions)
• Has EIT Coordinator review and initial checklist.
Initials show that the checklist has been
reviewed, but does not mean that Coordinator is
responsibility for compliance.
• Submit package to OP
35
Baking –Product Procurement
Checks and Balances
• EIT Coordinator will not initial checklist unless it
has been completed and appropriate
documentation is attached.
• EIT Coordinator is only person authorized to
approve exceptions/exemptions
• OP will only process IT purchase request with a
completed checklist. If they do not, OP assumes
responsibility for ensuring 508 compliance
36
Baking –Product Procurement
Checks and Balances
• Products that run on the USPTO enterprise
architecture must be successfully tested for
compatibility and 508 compliance by a testing
office in the OCIO. Products that fail are
returned to the vendor.
37
Baking –Product Procurement
Lessons-learned
• Much opposition from employees until they understood
the process.
• Emphasize functional requirements drive procurement,
not accessibility
• Prove to management and employees that you are part of
the solution, not the problem.
• Buyer signing/certify compliance is very effective
• Only had to threatened to stop procurement one time on
vendor who would not complete checklist and the word
got out to employees, OP and vendors.
38
Baking –Product Procurement
Lessons-learned
• Ensured that procurement requests were quickly
processed by the EIT Coordinator
• Whenever there was a major issue or problem,
immediately scheduled meeting with OGC and
buyer. Meetings sometimes lasted more than an
hour, but always found solution.
• Spot check of FY2003 end-of-year IT
procurements showed that every one was
processed according to the Section 508 procedure
39
Baking –Software Development
Certification: Project manager for creating new or
revising existing software. Signs checklist in
beginning to make the product compliant.
Responsibilities. Project Manager:
• Completes the checklist and certifies compliance
• Ensure final product is compliant
40
Baking –Software Development
Process:
• Developer meets with EIT Coordinator,
determines appropriate 508 standards and
completes checklist
• EIT Coordinator reviews and initials
• EIT Coordinator is the only person authorized to
grant exemption
41
Baking –Software Development
Process:
• If there is a contractor involved, the USPTO uses
the following statement on the contract to ensure
508 compliance:
In accordance with Section 508, the USPTO requires that all IT products
delivered under this Contract comply with the applicable EIT
accessibility standards issued by the Architecture and Transportation
Barriers Compliance Board set forth at 36 CFR part 1194.
42
Baking –Software Development
Process:
• Define functional requirements
• Determine which Section 508 standards are
applicable
• Provide requirements to testing area (TA)
• TA generates testing methodology
• TA tests and passes or fails package
43
Baking –Software Development
Checks and Balances
• Technical Review Board ensures 508 is in Life
Cycle Management process. If not, development
does not proceed
• System can not go into production until it has
been successfully tested for 508 compliance. No
exception for going into production and
correcting deficiencies later
44
Baking –Software Development
Checks and Balances
When a project manager challenges test results, the
EIT coordinator independently test the product
and makes final determination
45
Baking –Software Development
Lessons-learned
• Developers must have in depth knowledge of 508
standards
• Software standards are mostly and simply good
coding practices
• Always develop to the standards and not the
assistive technology (e.g., JAWS)
• Need independent and periodic evaluation of 508
standards during the development cycle.
46
Baking –Software Development
Lessons-learned
Testing Software
• Current no SW testing tools
• Use of screen reader can be effective eval tool
when used by experienced individual
• JAWS and compliance
• When testing, use two different tools
47
Baking –Web Documents
Certification: Individual creating document to be
posted
Responsibilities. Individual creating document:
• Completes the checklist and certifies compliance
• Obtains the Webmaster’s initials on the checklist.
48
Baking –Web Documents
Process. Individual coding document:
• Checks document to ensure it is compliance. If
there are questions, have the Accessibility Team
evaluate document
• Completes Section 508 Web checklist
• Has webmaster review and initial checklist
• Submits document to webmaster for posting
49
Baking –Web Documents
Checks and Balances
• Webmaster will not initial checklist unless it has been
completed signed
• Webmaster is only person authorized to approve
exceptions/exemptions
• Webmaster will only post a web document that has a
completed checklist. If the webmaster doesn’t obtain a
completed checklist, then the webmaster assumes
responsibility for ensuring 508 compliance
• Noncompliant posted documents must be corrected in a
specific time frame or they will be pulled off the web
50
Baking –Web Documents
Lessons-learned
• Most web authors do not understand Section 508. Must
have the webmaster as the focal point in the process and
must hold them responsible.
• Prove to management and web authors that making a
product compliant is not that difficult or time consuming.
Best way to accomplish this is set a precedent by quickly
correcting a web-site problem. Publicize the event as a
win-win situation.
• Publicly recognize outstanding compliant web-sites. We
made it a quarterly award that was posted so everyone in
PTO could read about it.
51
Baking –Web Documents
Lessons-learned
• Web authors signing document to certify compliance is
not as effective as signature certification in other area.
• Most effective tool was to threaten a couple times to not
post noncompliant documents or to pull noncompliant
documents from the web.
• Most government agencies have more web-site
requirements than just Section 508. All the requirements
needs to be posted so web authors are aware of them and
don’t just address Section 508.
52
More General Tips
• The only way to determine compliance is by
reading code
• Accessibility tools were not designed as test tools
• Always use two different testing tools when
evaluating compliance
• Most sighted people are not proficient enough in
JAWS to accurately evaluate compliance
53
Baking – Credit Cards
Certification: Card holder who signs for the credit
card purchase
Responsibilities. Credit card holder:
• For purchases under $2500, completes the
checklist and certifies compliance
• For purchases over $2500, completes the
checklist and ensures a completed Procurement
checklist is attached. Card holder still signs the
form, but 508 compliance is responsibility of
buyer.
54
Baking – Credit Cards
Background.
• Management thought everyone was using the
same worksheet. In fact, everyone had modified
it to fit their own needs.
• The worksheet was outdated and time consuming
to complete.
• Created standardized worksheet that was quicker
to complete and had space for individual
modifications
55
Baking – Credit Cards
Background.
Credit card purchases in the PTO fell into one of three areas:
• PC, printers, scanner could only be purchased from an
agency-wide, 508 compliant contract
• Many IT items were exempt (e.g., PDAs) or not IT (e.g.,
paper, office supplies, travel, conference fees)
• All other IT items had to be tested before they could be
used on the enterprise architecture. If it wasn’t 508
compliant, it had to be returned to the vendor.
This made it easy for the credit card holder to certify
compliance
56
Baking – Credit Cards
Process. Credit card holder:
• Reviewed the purchase request and ensured 508
documentation was attached for purchases over
$2500
• Completed and signed the worksheet.
• Processed the request once the Approving
Official signed the form
• All paperwork was retained for end of month
reconciliation with OP and Office of Finance
57
Baking – Credit Cards
Checks and Balances
• If the card holder did not require the buyer to
include 508 documentation for purchases over
$2500, then the credit card holder was
responsible for compliance
• The Approving Official reviewed the worksheet
for justification and documentation before
signing and authorizing the purchase
• OP and Office of Finance reviewed monthly all
credit card transactions
58
Baking – Credit Cards
Lessons Learned
• With the proper training, not one of the 140+
credit card holders objected to the process
• It is difficult to enforce compliance to the
process. Near term goal should be to raise level
of awareness. Compliance will follow,
• Having a standardized yet flexible worksheet
worked well and resulted in everyone adopting it
• Much confusion on what is and isn’t an IT
purchase (e.g., office supplies, paper)
59
Baking – Credit Cards
Lessons Learned
• The under $2500 procurements represent
probably the largest number of procurements and
probably the ones with the most questions
• Some resistance on IT purchases for specific
individuals who were not disabled. Common
sense should prevail.
• Many managers concerned that 508 will hinder
their ability to quickly purchase small items.
Have not found that to be the case.
60
And Even More General Tips
• Strike “undue burden” from your 508
vocabulary. Not an acceptable solution plus it
has demanding requirements.
• Visit agencies with operational 508 programs and
benchmark their processes
• Offer training for several years. It is the second
year that everyone starts to believe you are
serious about 508 and they had better listen in
class.
61
General Tips
Participate in high-level meetings, working groups,
and conference to better understand 508 at higher
level and have access to people who can answer
questions
Have ability to evaluate products to determine if
they are compliant or have problems. Best if you
act as an independent source.
62
General Tips
• There are no current evaluation tools to evaluate
software. Remember that accessibility tools were
not designed to evaluate products for compliance.
• Enforce small, easy to make compliant issues
first. Build employee/management expectations
that 508 is not difficult nor expensive.
• Constantly look for ways to promote 508. It is
amazing how easily get can get overlooked.
63
…enjoy your cooking
64