The wait is over! The January 18 delayed compliance date for the revised Section 508 standards is almost upon us. In Part 1 of our Section 508 Refresh series we focused on the background, history and highlighted some of the key changes influencing the revised Section 508 standards. In today’s article, we are shifting focus to the important initiatives that have taken place to better prepare agencies and vendors to support this new accessibility standard.
Original 508 vs Revised 508 Standards
If you are familiar with the original Section 508 law and technical standards – you also have the task of reassessing your understanding of law and technical requirements. Essentially, you need to be retrained. While you can expect a significant number of new requirements many are substantially the same but renamed or expanded upon.
To ease this transition the US Access Board has created a variety of comparative tables to reinforce what is new and where existing requirements may still live under a different name or category.
- WCAG 2.0 Level A and Level AA Success Criteria
- Final Rule Requirements for Software
- Final Rule Requirements for Hardware and Telecommunications Equipment
- Final Rule Accessibility Requirements for Support Documentation and Services
Defining Requirements
Before developing and testing new ICT that meets these new standards, organization must first accurately define which requirements apply. While a shift to a function-based approach should improve the accuracy, this exercise will place a greater dependence on the knowledge of the ICT’s feature-set.
To meet this challenge GSA is developing the Accessibility Requirements Tool (ART), expecting to launch it early in 2018. This step-by-step guide will assist in the accurate identification and documentation of accessibility requirements. Until it’s release, customers are encouraged to take advantage of instructions and checklists available in the Revised 508 Standards Toolkit.
WCAG 2.0
Though the Web Content Accessibility Guidelines 2.0 (WCAG 2.0) is only one of ten different standards incorporated by reference, this W3C Web Accessibility Initiative (WAI) standard will have perhaps the most significant influence with it comes to global harmonization and testing.
WCAG 2.0 is designed to apply broadly to different Web technologies now and in the future, and to be testable with a combination of automated testing and human evaluation. By incorporating these guidelines by reference, organization can leverage a considerable amount of technical documentation that has been developed by the community over many years.
While the inclusion of WCAG 2.0 is viewed as a significant leap forward please keep the perspective that this was initially published in 2008. In fact, the W3C Accessibility Guidelines Working Group W3C is well underway with important guideline updates in version 2.1 to address gaps with user needs and technology advancement. WCAG 2.1 has an expected publication date of June 2018.
It’s important to note that updates to this guideline will not automatically roll into Section 508. Section 508 will only require conformance with the Success Criteria defined in WCAG 2.0 Level A & AA until the law is revised again. At that point in time we may be discussing WCAG 3.0 – or beyond!
Conformance Documentation
When Section 508 originally became law federal procurement officials were expected to purchase the most compliant product – but how could they possible make this determination? Hence the creation of the VPAT® 1.0 format which was developed by the ITI – Information Technology Industry Council in partnership with GSA in 2001.
A VPAT® or Voluntary Product Accessibility Template® is a self-disclosing document produced by the vendor which details each aspect of the Section 508 requirements and how the product supports each criterion.
In October of this year, ITI released the final version of this accessibility conformance report — VPAT® 2.0. This new format was developed to align with the Revised Section 508 standards but also expands to other guidelines making the format more broadly used in the global marketplace. These standards include:
- Revised Section 508 standards – the U.S. Federal accessibility standard
- EN 301 549 – the European Union’s “Accessibility requirements suitable for public procurement of ICT products and services in Europe”
- WCAG 2.0 – W3C/WAI’s Web Content Accessibility Guidelines
Beyond this there are a number of other significant improvements in the document including an Evaluation Methods Used field to describe methods used to test the product’s accessibility which will provide more accountability in generating accurate conformance statements. The document also includes detailed instructions and best practice recommendations for greater consistency across manufacturers.