USACM and SIGCHI Comment on Section 508 Refresh on Accessibility

The U.S. Access Board is revising the accessibility standards that require federal agencies to make electronic content and customer premises electronic equipment equally accessible to employees and members of the public with disabilities. USACM and the ACM Special Interest Group on Computer Human Interaction (SIGCHI) submitted comments to the Access Board on the proposed standards and guidelines.

This “refresh” of the Draft Information and Communications Technology (ICT) Standards and Guidelines will jointly update the accessibility requirements under Section 508 of the Rehabilitation Act and Section 255 of the Telecommunications Act. The current standards were last updated in 2000 and went into effect in 2001.

The Section 508/255 Refresh seeks, in part, to ensure and improve accessibility in light of innovative and emergent developments within the computer and technology industries, such as webcasts, mobile applications and devices, interactive kiosks, laptop computers, onscreen keyboards, and wireless assistive devices. The Refresh also seeks to foster increased compliance through increased ease of use and understanding of the standards by federal agencies, their contractors, and equipment manufacturers.


“Innovative developments within the computer and technology industries will continue to revolutionize how the public, including people with disabilities, access federal government information and interact with government services,” said Harry Hochheiser, Chair of the USACM Accessibility Committee. “We strongly support the Access Board’s decision to adopt the leading international standard for web accessibility. We anticipate the result will be a broader range of cost-effective software and equipment options, automated testing and evaluation tools, and built-in accessibility features that will help federal agencies provide greater accessibility to government information and services.”

USACM Accessibility Committee member Jonathan Lazar is pleased with one significant change from past versions: “There is now an increased focus on satisfying functional performance requirements, even when technical design requirements are met. A technical requirement, when met, may theoretically provide access to information, but it does not guarantee that users will actually be able to effectively use that information resource. Performance-based requirements, which focus on outcomes rather than specific methods or technologies, provide greater flexibility to respond to the rapid changes in technologies.”

Highlights from the USACM/SIGCHI public comment include:

  • Harmonization with International Standards
    We support the Access Board’s decision to incorporate by reference international standards, where appropriate, rather than creating duplicate or additional standards specific to the federal government. As many commercial companies already make products compliant to international standards for the private sector, a harmonized framework of accessibility requirements across public and private efforts will foster industry efficiencies, costs reductions, and increased built-in accessibility features in ICT services, products, and equipment. To allow for updates and evolutions of referenced international standards, we encourage the Access Board to include “or later” after references to a specific version of an international standard.
  • Functional Performance Is Essential
    Requirements that focus on functional performance criteria rather than specific technical provisions will better promote the values of accessible participation, technical flexibility, and innovation. We concur with the proposed requirement that functional criteria must always be met, even when the technical requirements are met. Technologies must be not only accessible but also usable by people with disabilities.
  • Technical Assistance to Federal Agencies
    The Access Board, as a trusted resource with technical expertise, should be ready to assist federal agencies by providing information about implementations, tools, and audit resources that will help covered entities achieve compliance. Ongoing assistance could include updates on best practices, case studies, examples of successful implementations, developer and authoring toolkits, testing and evaluation tools, training opportunities, and relevant online resources.

The Access Board will consider the public comments received and then issue a proposed Final Rule, followed by another round of public comment before it issues the Final Rule.

See also: Statement by Harry Hochheiser and Jonathan Lazar on the USACM/SIGCHI Comments

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