Federal Web Business Council Meeting 04/11/2001

Here are notes from a meeting of the Federal Web Business Council, held downtown Washington DC. The speakers were as follows:

• Basil White, Webmaster, Veterans' Affairs Administration.
• Keith Thurston, Assistant to the Assistant DAA, Office of Information Technology, GSA
• Terry Weaver, Director, IT Accomodation, GSA
• Mary L. Mobley, Attourney, Civil Rights division, Department of Justice
• Linda Nelson, Federal Acquisition Policy Division, GSA

Important points of law and technology

• Even though you are not responsible for section 508 violations for existing materials (ie already existing webpages created before 6/21/01), you are still responsible for making them accessible under section 504, which states that you must provide an accessible alternative to those pages if you cannot make them accessible in and of themselves. This could include, for items such as graphics that are uninterpretable in a non-visual manner (satellite maps of Washington DC, electronics diagrams, photographs of cancer cell tissue samples compared to non-cancerous cells, etc), providing what textual description you can othese items that makes a reasonable effort to explain these things. In short, even though you are off the hook on Section 508 for legacy pages, you still have similar obligations under existing section 504 law.
• Adobe PDF files in graphic format are NOT exempt from this alternative. If you have files that are in PDF format that cannot be translated into screen-reader interpretable format, you must create HTML or text-based alternatives to them.
• Just putting up a sign saying "we're working on it" is insufficient. You must make reasonable accomodation to accessibility. If you have pages that you know will not be done by the deadline of 6/21, you must provide an alternative for disabled people to gain access to that information. One example of that is to post a phone number and/or email address on each page that fits those criteria for someone who cannot traditionally read the page's information to use to get that information in a format they can use.
• The only pages exempt from this requirement due to national security concerns are those which directly support military intelligence and highly sensitive information, command and control infrastructure, or other systems that have immediate consequences for field operations. Pages NOT exempt include personnel records, budget and fiscal management, and other logistics and support pages.
• VERY IMPORTANT: neither A-Prompt, Bobby, nor the Webable tool actually prove 508 compliance. They are valuable testing tools to help you find major problems, but simply passing their tests is not enough. Alt tags are a good example. Bobby cannot verify how meaningful an ALT tag is, just that it exists. It is up to webmasters, developers and content creators to make sure that the tags they provide are not only present but convey useful meaning. A-prompt was touted though as being a superior tool to Bobby because it can be modified to set certain standards, in effect, to learn as the 508 regulations gel further over time. A-prompt also has a feature that enables you to log your testing and modifications results which could prove invaluable should you have to respond to a 508 request.
• There is currently no such thing as "508 compliant certification". The rules for what makes 508 compliance are still a moving target, so there is no official "certification". Another reason for this is that by establishing some kind of "certification", whichever organization that does the certifying will become the authority and watchdog for this process and thus remove the burden of actually performing 508 compliant design and retrofitting from the development community. DOJ, GSA, and the Access Board do not wish to take on this burden, nor do they want the government web community to feel they are no longer responsible for performing this task.
• The Access Board's standards for 508 compliance are THE current standard to be followed by all government entities. The W3C guidelines are useful, but just that, guidelines. If a page does not meet the Access Board requirements, regardless of which tools approve your web design, it is NOT 508 compliant.
• LOTS was said about PDF files. The newest version of Adobe Acrobat has formatting tools that can help make new documents readable by screen readers and other access-enabling devices/software. However, the greatest caveat to this is that it takes effort on the end-user's part to deliver this. The end-user must bring the files into PDF format as prints from some kind of text file, be it a word-processing document, or via an OCR-type input. A direct scan will more likely than not just render one great big jpeg file that is still meaningless to a screen reader. There are also third-party plugins that supposedly assist in rendering new and existing graphical PDF's into screen-reader interpretable formats. One such product is called Magellan, from a British software company. Neither they nor the other makers nor Adobe themselves make any promises/guarantees about the success of such conversions, as noted before, due to the graphic nature of a non-text-formatted PDF.

Specific developers' tips

Good Practices:

• A good practice for enabling pages that you cannot make compliant immediately is to add an email link and contact information to direct users to a way to get accessible information sent to them. Adding email links to each page that use the URL of the page from which the user clicks the email link in the subject are a good idea. This will cut down on the amount of back-and-forth email with the end user in trying to ascertain where their problem lies and what page they need help interpreting.
• Using whatever tools you have at your disposal, figure out what your top ten to twenty webpages/sites are, and approach them first. Add a standard banner that directs users to alternative sources for information to all other pages until they have been retro-fitted.