Betsy L. Sirk Section 508 Coordinator NASA Goddard Space Flight Center IT Summit 2010 Section 508 and You: Accessible Technology August 18, 2010 Betsy L. Sirk Section 508 Coordinator NASA Goddard Space Flight Center

Agenda What is Section 508? Scope Current Technical Standards Proposed New Standards NASA Section 508 Compliance Resources

What is Section 508? Section 508 of the Rehabilitation Act of 1973 as amended by Congress in 1998 requires that Federal employees with disabilities have access to and use of information and data, comparable to that for Federal employees without disabilities, unless it is an undue burden to do so. Section 508 also requires that disabled members of the public who are seeking information or services from a Federal agency, have access to and use of information and data comparable to that for members of the public without disabilities. Section 508 applies to Federal agencies, including the U.S. Postal Service. Contractors providing services or products to Federal agencies must provide Section 508 compliant deliverables.

Scope Electronic and information technology (EIT) products procured, developed, maintained, or used by a Federal agency, including products that store, process, transmit, convert, duplicate, or receive electronic information. Examples: copiers, computers, fax machines, software, hardware, information kiosks, websites, telecommunications products Limited number of exceptions apply: EIT incidental to a contract (not part of the government deliverable), EIT deemed to be for national security, EIT used in areas frequented only by service personnel for maintenance, repair or occasional monitoring. Undue burden, defined as significant difficulty or expense, is rarely invoked. Requires approval of Center legal counsel. You are not required to fundamentally alter your requirements if compliant solution is not available.

Current Technical Standards Section 508 Technical Standards published in the Federal Register in December 2000. The Federal Acquisition Regulation was amended to include the Section 508 Standards in April 2001. Enforcement of the Section 508 standards began June 2001. Standards and Technical Specifications organized by types of “products”: 1194.21 Software Applications and Operating Systems 1194.22 Web-based Information and Applications 1194.23 Telecommunications Products 1194.24 Video and Multimedia Products 1194.25 Self Contained, Closed Products 1194.26 Desktop and Portable Computers

Proposed New Standards Process Overview United States Access Board issued an Advance Notice of Proposed Rulemaking (ANPRM) to update its standards for electronic and information technology (Section 508), Telecommunications Act Accessibility Guidelines (Section 255), and its Americans with Disabilities Act Accessibility Guidelines on March 22, 2010 Public hearings were held in March and May 2010 Public comment period ended June 21, 2010 Access Board is analyzing comments and developing proposed rule and regulatory assessment, followed by a submission to the Office of Management and Budget Notice of Proposed Rulemaking will then be published in the Federal Register, followed by another public comment period, before a final rule is issued (possibly next year).

Proposed New Standards What Has Changed Electronic and Information Technology (EIT) is now also referred to as Information and Communications Technology (ICT) Draft is organized by product features or capabilities rather than “types of products”. Example: IN OUT “volume control” “Telephone” “reach ranges” “copy machines” “Navigation” “Internet/intranet apps” Definition of content (what is covered). Example: Electronic Content: An Official Communication of the Agency, which supports the Agency’s mission. Covers Documents, Emails, Attachments, etc. Exception: Electronic content stored for archival purposes or retained, solely to preserve the exact image.

Proposed New Standards What Has Changed, cont’d Advisory Notes next to provisions. Example: E103.3.1.2 Medium.  This part applies to Federal electronic content regardless of medium. Advisory E103.3.1.2 Medium.  Electronic documents, for example, are covered regardless of whether posted on a website, attached to an email, or saved on a CD, flash drive, office server, or other medium. Reflects current technology Links to Announcement of Proposed Rulemaking and draft text: ANPRM: http://www.access-board.gov/sec508/refresh/notice.htm Draft Text: http://www.access-board.gov/sec508/refresh/draft-rule.htm

Proposed New Standards Text Organization Chapter 1- 508 (EIT); Chapter 1 – 255 (Telecommunications Act) Chapter 2 Functional Performance Criteria Chapter 3 Common Functionality Chapter 4 Platforms, Applications and Interactive Content Chapter 5 Electronic Documents Chapter 6 Synchronized Media Content and Players Chapter 7 Hardware Aspects of ICT Chapter 8 Audio Output from Hardware Chapter 9 Conversation Functionality and Controls Chapter 10 ICT Support Documentation and ICT Support Services Americans with Disabilities Act (ADA) Amendments

NASA Section 508 Compliance NASA Technical Standards amended to include assistive technologies and developer tools Draft NASA Procedural Requirement (NPR 2800.2, Electronic and Information Technology Accessibility), outlining NASA roles and responsibilities for Section 508 compliance, is in review cycle NASA Section 508 Website enhancements planned Compliance Checklists Resources for Coordinators/Developers/Users Coordination of Center Resources Section 508 Training module developed with input from Center Section 508 Coordinators; implementation TBD

NASA Section 508 Compliance continued Section 508 Coordinator named for NASA Shared Services Center Section 508 provisions considered in the development of agency procurement initiatives, including I3P At the Goddard Space Flight Center, Section 508 Coordinator and Chief Technologist from the Office of the Chief Information Officer partnering with the Disabilities Program Manager to allow usability testing of new technologies (e.g. iPad, iPhone) by employees Successful implementation of Section 508 requires all federal employees and support contractors involved in the design, development, procurement, or use of Electronic and Information Technology to understand how the requirements of Section 508 apply to their business processes.

Resources www.section508.gov Current listing of NASA Section 508 Coordinators by Center: www.nasa.gov/accessibility/section508/sec508_coordinators.html Other helpful sites for technical assistance: www.access-board.gov www.section508.gov Questions about this presentation: Email: betsy.sirk@nasa.gov Phone: 301-286-0150