508 (weeks to get to a) Refresh?

By Chris Law, PhD, Senior Accessibility Analyst

In a recent industry show-and-tell, Paul Schroeder of the American Foundation of the Blind gave us all a good chuckle when he said “I didn’t realize 508 referred to the number of weeks it would take to get the standards updated!”

February 2015 saw the publication of the (third) Notice of Proposed Rulemaking by the Access Board. The document updates Section 508 standards that cover the accessibility of electronic and information technology within the federal government and updates Section 255 guidelines that cover access to telecommunications and apply to providers and equipment manufacturers. Collectively, this is known as the “Information and Communications Technology (ICT) Refresh.” The goal is to respond to changes in technologies, industry trends and to ensure consistency in accessibility across the variety of ICT covered.

What’s new in terms of technical requirements in the 508 Refresh has already been discussed widely. For example, for any non-web software, a set of interoperability requirements (Chapter 5, Subsection 502) lay out the basic functions and services that software should follow. This replaces the current technical requirements for software (§1194.21). But a large part of the Refresh is going to be the jump from the current (i.e., outdated) web and software standards to the newer, internationally recognized Web Content Accessibility Guidelines (WCAG 2.0). Anything that is web-based (on a phone, tablet, or traditional PC) that meets WCAG 2.0 AA will be deemed Section 508 or Section 255 conformant.

The current push for many agencies is to be “508-Refresh-Ready.” As part of New Editions’ program management support work at DHS, our staff members have been actively involved in shaping and preparing the software and web DHS Section 508 Compliance Test Process for Applications to be WCAG 2.0 ready. We provide associated ”Trusted Tester” training courses to train programmers and QA staff on this “Refresh Ready” DHS Test Process.

The proposed rule now expands requirements to cover electronic documents, including MS Word, PowerPoint, Excel, and Adobe PDF. Our team has also worked with the Accessibility Electronic Document Community of Practice (AED COP). New Editions helped ensure sure that WCAG 2.0 requirements were correctly mapped—along with the current 508 requirements—to the AED COP’s Baseline Requirements. The recently released Baseline Tests for Accessibility for MS Word  document is the foundation document for MS Word Section 508 interagency agreed-upon test processes.

Another new requirement (Subsection 504) calls for authoring tools to have a mode of operation that allows users to create conforming content. Many of us in the field have wondered why word processing programs have not had a mode to prompt authors to include accessible elements before. This new requirement should address that need for any kind of authoring tool, including web content, multimedia content, and telephone IVR system content.

If you want to contribute your thoughts on accessibility, there is still time to comment on the proposed rule. Written comments must be postmarked and electronic comments must be submitted on or before May 28, 2015.

In addition to the technical requirements, the rulemaking history in the document (pages 16-37) makes for interesting reading. It’s a history of the back-and-forth between subject matter experts, industry, the AT community, and the government. It’s been a massive investment of time and energy by the Access Board and many others. This history provides some context on why things have taken so long to get to where they are now, and should not be overlooked in its importance for practitioners in this field.

While the official kickoff date for revising Section 508 isn’t totally clear, the filing date for the charter for the revision committee was July 30, 2006. Five hundred and eight weeks later would be April 24th, 2016. Current estimates put the effective date of the revised 508 somewhere in that timeframe. Paul, your prediction may yet come true!

Chris Law, PhD, is a Senior Accessibility Analyst with expertise in organizational behavior, corporate culture and disability. He has over 20 years of experience in IT accessibility, Section 508 and universal design.