2 Summary of Recommendations

2.1   Subpart A
2.2   Subpart B - Functional Performance Criteria
2.3   New Organization of the Technical Requirements in Subpart C
2.4   Sections on Support and Implementation in Subpart D
2.5   New Advisory Notes
2.6   Provisions Considered, But Not Recommended
2.7   Applying the Recommendations to Sections 508 and 255


Information and communications technology (ICT) that is accessible to and usable by people with disabilities allows the performance of regular operating functions of the ICT, including input and control functions, operation of mechanical mechanisms, and access to information displayed in visual and auditory form.4 Interfacing with assistive technology (AT) used by people with disabilities to access ICT is important to providing access to ICT.  The ICT and AT should use documented interfaces to interoperate with each other, and where possible not interfere with each other.

The provisions recommended in this report apply to a full range of ICT, consistent with the applicable statues, including those used for communication, duplication, computing, storage, presentation, control, transport and production.  Our goal is to make these products accessible to as wide a range of people with disabilities as possible including people with:

  • Visual disabilities (blindness, low vision, and lack of color perception)
  • Hearing disabilities (hard of hearing and deafness)
  • Physical disabilities (e.g., limited strength, reach or manipulation, tremor, lack of sensation)
  • Speech disabilities
  • Cognitive disabilities (e.g., disabilities affecting reading, language, learning, thinking, remembering, sequencing, etc.)
  • Other disabilities (e.g., photosensitive seizure disorders), and individuals with some combinations of these conditions (e.g., deaf-blindness).

2.1   Subpart A

Subpart A includes material that explains how the provisions are to be used including:

  • Separate purpose statements for Sections 255 and 508
  • Separate application statements for Sections 255 and 508
  • Additions and some changes to the general exceptions
  • Additions and changes to the definitions
  • Equivalent facilitation has not been changed

2.2   Subpart B - Functional Performance Criteria

Subpart B includes the Functional Performance Criteria (FPC), which refer to different disability categories and the necessity of providing access to the functionality of products.  The FPC have been modified from the previous version. They now include a note on the role of assistive technology in meeting the Functional Performance Criteria. However, there is an unresolved issue of when and how the criteria are used, which the Committee is sending to the Access Board for its consideration and final decision.
The FPC now precede the Technical Provisions because they help frame the Technical Provisions. The move of the FPC to this location was a topic of much discussion for the Committee. Their position in this document, as a report to the Access Board and not a regulation by itself, has no implications for interpretation or enforcement.

2.3   New Organization of the Technical Requirements in Subpart C

General Technical Requirements
Requirements for Hardware Aspects of Products
Requirements for User Interfaces and Electronic Content
Additional Requirements for Audio-Visual Players or Displays
Requirements for Audio and/or Video Content
Additional Requirements for Real-time Voice Conversation Functionality
Additional Requirements for Authoring Tools

The organization of the technical requirements in the current Section 508 standard no longer matches the types of ICT products currently or likely to become available. The groupings in the standard currently in force are based on product types such as web, software, and telecommunications. Since the time that these groups were first created, however, many of these technologies have evolved and many of their various functions have converged and overlapped. It has become difficult to determine which provisions should be applied to a product using the current organization of the provisions5. An example of this is how telephones have changed from a device used to talk to another person, to a tool for accessing the web and reading emails. We also concluded that the organizational structures of the Section 255 guidelines and Section 508 standards would not work for harmonization or current product designs.

We therefore re-arranged the technical requirements in Subpart C into categories based on product characteristics or features.  This allowed us to address the convergence of features and functionality in ICT. Instead of attempting to define the difference, for example, between “software” and a “web application,” provisions are organized by how the products are constructed and used. This, and other similar groupings in the report, was done to eliminate duplication of requirements, and make it easier for designers to ignore or skip over provisions that did not relate to their products. The categories are as follows:

General Technical Requirements

This is a new category that consolidates provisions that apply to all ICT to eliminate duplication of requirements that appeared in more than one section under the current Standard.

Requirements for Hardware Aspects of Products

These provisions apply to any ICT with hardware and have been broken down into two groups. The “All Products with Hardware” group of provisions applies to all products with hardware. The “If the Product has Speech Output or Throughput” group applies only to hardware for ICT with speech output or throughput, to ensure that products do not interfere with hearing technologies, and include appropriate audio connections and controls and limits for volume.

Requirements for User Interfaces and Electronic Content

Technological changes have brought web and software interfaces into close correspondence.  In some cases a web-based application offers the same functionality as an application installed on a computer.  At the same time, electronic content has posed a problem for end users, content authors, and Section 508 officials concerned when electronic content is considered E&IT and subject to Section 508 technical requirements and functional performance criteria.  The Access Board asked the Committee to address both issues.

The interface behavior of physical products, such as the relationship between button presses and the contents of a copier’s display, is a function both of the hardware and the software, with the software controlling the behavior.  This interaction risks creating duplicate requirements in the hardware and software sections of the Standard.

Our response was to develop recommendations to harmonize the requirements for user interfaces and electronic content.  The provisions in this section apply to any electronic content, including web pages or other documents and information, and to any software and web user interfaces. The definition of content includes as examples:  word processing files, presentation files, spreadsheet files, text files, portable document files, and web based content.

There was a difference of opinion on the Committee as to whether the provisions in this section should apply to hardware user interfaces, or only to software. One view is that provisions in this section came from the current Section 508 requirements for Software Applications and Operating Systems (Section 508 1194.21), the Web-based Intranet and Internet Information and Applications (Section 508 1194.22), or the Web Content Accessibility Guidelines (WCAG) 2.0 and therefore should not apply to hardware displays. The other point of view is that the behavior of hardware is controlled by software so this section applies to the interface aspects of hardware.

Additional Requirements for Audio-Visual Players or Displays

These provisions apply to ICT that includes audio-visual player or display functions (including products such as televisions, tuners, computer equipment, web browser plug-ins, software players, and kiosks). They include requirements to ensure that captions and supplemental audio playback (for example, video description) are available, and that there is equivalent access to these features.

Requirements for Audio and/or Video Content

These provisions apply to content that includes audio, video, or both audio and video, including both pre-recorded and real-time audio. They include requirements for captions and video description, as well as an equivalent way of selecting interactive elements in synchronized media, previously often referred to as multimedia.

Additional Requirements for Real-time Voice Conversation Functionality

These provisions apply to any software or hardware that provides the ability for voice conversation in real time. They include requirements for real-time text (RTT), voice conversation via interconnected VoIP, voice messaging and other interactive voice systems, caller ID, and real-time video communication.  Although many of these requirements originally came from Section 255, they also apply to ICT products covered by Section 508 that include telecommunications-like functionality.

Additional Requirements for Authoring Tools

These new provisions apply to authoring tools, defined as “software intended to create or modify content for publication in one or more formats that support compliance with the user interface and content provisions.” They include requirements for how these tools support the creation of accessible content.

2.4 Sections on Support and Implementation in Subpart D

Information, Documentation and Support
Implementation, Operation and Maintenance

These provisions address how ICT is deployed for use in federal agencies after procurement.

Information, Documentation and Support

These provisions cover product documentation and technical support. New provisions were added to clarify the types of things that need to be documented and the kinds of support and training that must be accessible.

Implementation, Operation and Maintenance

During the Committee’s deliberations it became clear that an accessible product may need to be set up in a particular way so as to provide the benefit of the accessibility to the federal employee or member of the public with a disability.  These new provisions refer to specific actions that must be taken subsequent to procurement by agencies in order to expose the accessibility to the product’s users. Many of these provisions apply only to Section 508.

2.5   New Advisory Notes

In some cases, the Committee agreed on the need for a provision, but could not agree on how to write the requirement with sufficient precision. In other cases, the Committee concluded that an issue could be better addressed as an advisory note issued by the Access Board. These recommendations are gathered in one place for convenience. They are written as guidelines, using “should” rather than “must” to indicate that they are best practice rather than provisions.

2.6   Provisions Considered, But Not Recommended

In the course of the Committee’s deliberations we discussed many ideas for provisions that did not become a final recommendation.  Most of these were factored into other provisions, or were discarded as unnecessary.  A small number of provisions were considered by the Committee, and had one or more advocates, and one or more opponents.  Those provisions are recorded here, in order to deliver a true report of the Committee’s deliberations and the range of positions taken on issues raised.

2.7   Applying the Recommendations to Sections 508 and 255

One of the charges to the Committee was to update both the Section 508 Standard and the Section 255 Guidelines at the same time. Some of the individual provisions that applied to each of these laws were in conflict, and both were in need of significant technological updating, especially concerning text communication and voice over Internet Protocol (VoIP). Access Board staff suggested that the Committee create, if possible, a single harmonized set of consistent requirements that could be applied for both contexts.

The Committee looked at the guidelines originally developed by the Access Board, many of which were adopted by the FCC. The FCC rules apply to information and documentation associated with the covered products, as well as information and documentation necessary to use the covered products.  This information and documentation includes user guides, bills, installation guides for end-user installable devices, and product support and communications. (47 CFR §§6.11 and 7.11). Finally, the Commission’s rules cover equipment used for voicemail or interactive menu services (47 CFR §7.1)

The Committee formed a Task Force to work on 255/508 differences and develop harmonized proposals where possible, or separate text where necessary. The Committee accepted the Task Force report, which determined that the recommendations generally apply to both Section 508 and Section 255, except in some specific provisions. In cases where the separate environments of the two regulations require it, the provisions explicitly document this, either within the text of a recommended provision, as a note attached to a provision, or in other text.

Specifically, the Committee agreed that technical standards that would improve the accessibility of any of the items covered by Section 255, whether a phone or VoIP device, a printed user guide, or a web-based billing function, are candidates for inclusion in the Access Board’s Section 255 guidelines.
We believe that this report renders the Committee's best judgment on these issues, and points towards significant opportunities for harmonization.  At the same time we have explicitly called out situations and applications that should refer to the separate environments in which Section 255 and Section 508 operate, either within the text of a recommended provision, as a note attached to a provision, or in other text.