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Executive
Summary & Recommendations(1)
Introduction
Prior to the late 1980's, computers were generally easy for most
people with disabilities to use. People who were blind, for example,
could use the same word processing software packages as everyone else.
Instead of relying on monitors, they used assistive technology -- called
"screen readers" -- to read in a synthesized voice all the
text and punctuation that a sighted person would read on the computer
monitor. All who used early word processors used keyboard commands to
interact with the software. To print a document, for instance, one would
simultaneously hit the "control" and "P" keys --
something that could be done as easily by blind people as others.
As technology grew more sophisticated, many changes that generally
made it easier for nondisabled people to use computers often created
barriers for people with disabilities. For instance, software that
required someone to issue commands by "pointing and clicking"
using a computer mouse became inaccessible to those who could not see
icons. Although the solutions were simple and inexpensive, little
thought was given to preserving accessibility. For example, if word
processing software allows the user to choose between entering
"control-P" to print or clicking on a printer icon, then blind
people can use the print function as easily as everyone else.
In the past, most agencies did not focus on the extent to which their
mainstream technology was accessible to persons with disabilities. Some
employees with disabilities lost jobs or became underemployed due to
technological advances that unfairly screened them out from the
workplace, even when they otherwise had the skills, intelligence, and
knowledge to accomplish their jobs.
Section 508 of the Rehabilitation Act
An amendment to section 508, signed by President Clinton in August
1998, requires the Attorney General to report to the President on
accessibility of federal electronic and information technology (EIT) --
such as federal Web sites, telecommunications, software, hardware,
printers, fax machines, copiers, and information kiosks -- to people
with disabilities. Section 508 of the Rehabilitation Act, 29 U.S.C.
§ 794d, as amended.
Section 508 prohibits federal agencies from procuring, developing,
maintaining, or using EIT that is inaccessible to people with
disabilities, subject to an undue burden defense. "Undue
burden" generally means a significant difficulty or expense.
On March 31, 2000, the Architectural and Transportation Barriers
Compliance Board (Access Board) published a Notice of Proposed
Rulemaking containing draft accessibility standards to implement section
508. 65 Fed. Reg. 17346. Once final, these Standards will be
incorporated into the Federal Acquisition Regulation (FAR), to which
most agencies are subject. Agencies not covered by the FAR will
incorporate the Access Board's Section 508 Standards into their own
procurement regulations.
The General Services Administration (GSA) and the Access Board share
statutory authority to provide section 508 technical assistance. 29
U.S.C. § 794d(b).
Although the law technically applies to federal agencies' existing
EIT, by its own terms it is unenforceable except for products procured
on or after August 7, 2000; retroactive modification of existing EIT is
not required. Agencies continue to have long-standing obligations under
sections 501 and 504 of the Rehabilitation Act to provide reasonable
accommodations to qualified individuals with disabilities (including
members of the public and federal employees) upon request and to avoid
disability-based discrimination, generally. 29 U.S.C. §§ 791,
794. Agencies must comply with section 508 regardless of whether they
have employees with disabilities or serve members of the public with
disabilities.
Built-in assistive technology is not required where it is not needed.
Section 508 does not require every workstation or every EIT product to
be fully accessible to persons with disabilities. Products like desktop
computers do not have to be outfitted with refreshable Braille displays;(2)
rather they must be compatible with refreshable Braille displays, so
that if an individual who is blind needs one as a reasonable
accommodation, he or she can use it with the agency's standard
workstations.
Section 508 does not require private companies who market EIT
products to the Federal Government to modify the EIT products used by
company employees, or to make the companies' own Internet sites
accessible to people with disabilities. For instance, if a manufacturer
wishes to sell desktop computers to federal agencies, it must ensure
that these computers comply with the Access Board's Section 508
Standards or agencies will be unable to purchase them. The company
telecommunications systems, Internet pages, and other EIT used by
company employees (including desktop computers not intended for federal
use), are not subject to section 508.
The Department of Justice is not charged with enforcing section 508.
Members of the public and employees with disabilities, however, may:
- file administrative complaints with agencies they believe to be in
violation of section 508; or
- file private lawsuits in Federal district court.
29 U.S.C. § 794d(f).
In August 2001 and every 2 years thereafter, the Attorney General is
required to provide updated reports to the President and Congress. These
subsequent reports will discuss improvements in the degree of
accessibility of federal EIT and will also report on the resolution of
section 508 complaints filed against federal agencies. 29 U.S.C.
§ 794d(d).
The Report
The Department of Justice's Civil Rights Division has prepared this
Report. It contains the results of the first Executive Branch-wide
section 508 evaluation. It also recommends specific inexpensive,
cost-effective, and easily accomplishable measures to improve the extent
to which federal agencies' technology is accessible to people with
disabilities. By following these recommendations, agencies will
facilitate their compliance with the general nondiscrimination and
reasonable accommodation requirements of sections 501 and 504 of the
Rehabilitation Act. The Department's recommendations make the most of
existing resources and build upon model agency practices.
The Report is intended to provide guidance to:
- federal information technology personnel, policy makers, and
procurement officials,
- private sector technology designers, manufacturers, and vendors,
and
- disability advocates.
History of the Department of Justice's
Efforts
In April 1999, the Attorney General sent a package of detailed
self-evaluation materials and resource guides to federal agencies and
departments, including the U.S. Postal Service, to assist them with
accomplishing meaningful section 508 self-evaluations. Agencies were
instructed to evaluate their procurement policies and practices,
telecommunications products and systems, and their most commonly used
Internet pages, software applications, information kiosks and other
information transaction machines, and other electronic office equipment
such as fax machines, copiers, and printers. Products were generally
evaluated in 2 ways:
- using objective checklist-style questions, and
- using more subjective evaluation techniques, such as consulting
with people with disabilities and viewing Internet pages with
text-only browsers and other types of assistive technology.
To create this Report, the Department collected objective survey data
from 81 agencies, including over 250 components, on an interactive
Internet database site. A list of these agencies is attached as General
Appendix A (Categories of Agencies). Subjective "overall agency
evaluations" were also provided to the Department.
The Department established a section 508 home page (http://www.usdoj.gov/crt/508)
to make available to a wide audience the Department's section 508
resource guides and self-evaluation material. Federal and state
agencies, the technology industry, and disability advocates regularly
use this web site. From the week ending April 12, 1999, through the week
ending March 13, 2000, we recorded 201,432 "hits" on this
site.
For the last 18 months, representatives of the Department of Justice
have met with countless agencies to help them understand the importance
of section 508 and to assist them with their self-evaluations.
This Report would not have been possible without assistance from the
Department of Education, the General Services Administration, the
Federal Communications Commission, and other agencies. The Department
also learned from private sector leaders in the field of technology
accessibility, including the World Wide Web Consortium's Web
Accessibility Initiative and the University of Wisconsin's Trace Center.
General Findings and Recommendations
While several agencies are models of accessibility, the data suggest
the need for improvement in the accessibility of federal EIT to persons
with disabilities. Most agencies can also improve the extent to which
disability accessibility issues are incorporated into their mainstream
technology procurement contracts.
The most significant challenge posed by section 508 is the need for
coordination between those with technological expertise and those with
knowledge of disability access issues. The rapid pace of technology
innovation can further complicate the issue. Increased inter- and
intra-agency coordination among relevant personnel -- including
information technology personnel, procurement officials,
telecommunications staff, equal employment opportunity professionals,
and end users with disabilities -- along with the private sector, would
benefit everyone.
For increased coordination and cooperation to be efficient and
effective, the Department recommends the following:
Increased Coordination
1. The President should issue a Technology Accessibility
Coordination Directive to:
a. Revitalize the Interagency Disability Coordinating Council (IDCC),
as set forth in 29 U.S.C. § 794c, with the Attorney General as
Chair, consistent with Executive Order 12250, 29 U.S.C. § 2000d-1;(3)
b. Direct certain Federal agencies (including the General Services
Administration, the Department of Defense, and the Department of
Transportation), and invite other agencies (including the Federal
Communications Commission and the U.S. Postal Service) to participate
as nonstatutory members in the IDCC; and
c. Direct the Department of Justice, in consultation with the Office
of Personnel Management, the EEOC, and the Access Board, to issue
guidance to agencies clarifying the relationship among sections 501,
504, and 508 of the Rehabilitation Act.
2. The Universal Access Working Group (UAWG).(4)
Each cabinet level, large, and mid-sized agency, along with
representatives from small and very small agencies, should join the
inter-agency UAWG. See General Appendix A (Categories of
Agencies). The UAWG has been an instrumental force in advocating for
accessible technology throughout the Federal Government and private
sector. Its relevance would be increased if its members were designated
as their agencies' representatives, rather than participating as
individual volunteers, and if more agencies were involved.
3. 508 Coordinators. Each agency should designate Coordinators
for purposes of complying with the substantive and reporting
requirements of section 508. Agencies should either select multiple
Coordinators -- to represent each of the agency's information
technology, telecommunications, disability accommodations, and other
relevant sectors -- or a single representative to act as an intermediary
among these sectors. The Section 508 Coordinators of cabinet level,
large, and mid-sized agencies, along with representatives from small and
very small agencies, should attend UAWG meetings as representatives of
their agencies. See General Appendix A (Categories of Agencies).
A list of all Section 508 Coordinators should be developed and
distributed among all agencies. The Section 508 Coordinators should meet
regularly with agencies' Section 504 Coordinators.
Technical Assistance
1. The General Services Administration (GSA) and the Access Board,
which have statutory authority for providing technical assistance under
section 508, should share in the following responsibilities:
a. Information Hotline. An information hotline should be
established for federal agencies, persons with disabilities, and the
IT industry. The Department of Justice's Americans with Disabilities
Act Information Line should serve as a model.
b. Technical Support Center. An interagency technical
assistance support center should be established where agencies can
receive specific, hands-on assistance tailored to their individual
concerns. The Job Accommodation Network of the President's Committee
on Employment of Persons with Disabilities at the Department of Labor
should serve as a model.
c. Internet Resources. An Internet message board and listserv
(an e-mail mailing list for discussion among a group of users) should
be maintained where knowledgeable agencies can post solutions to
particular problems and where agencies trying to address EIT
accessibility issues can post questions. Agencies that have developed
evaluation criteria, techniques, and reports of existing EIT products
should make these available to other agencies using these Internet
resources [recommendation of the Social Security Administration].
2. GSA should do the following:
a. Accessible Products Clearinghouse. GSA should be directed to
act as a clearinghouse for information regarding accessible EIT
products. Any manufacturer's information regarding accessibility of
EIT products should be made available to all federal contract officers
and their technical representatives through this Clearinghouse. The
Energy Star and Y2K programs may provide models on which to build.
b. Training Clearinghouse. A clearinghouse for accessible
training resources -- and training regarding accessibility -- for
management, IT and procurement personnel, and end users with
disabilities should be established. Vendor information regarding
accessible training opportunities should be made available to all
agencies through this Clearinghouse.
3. Mechanism for Reliable Information. The Federal Government,
in partnership with the private sector, should explore the best
mechanism to provide reliable information (including information
regarding the comparative usability of EIT products for people with
different types of disabilities) to manufacturers, vendors, and
procurement officials.
Other General Implementation
Recommendations
1. Alternative Dispute Resolution. Each agency should
establish voluntary alternative dispute resolution mechanisms and make
them available to members of the public and employees with disabilities
as a means to resolve allegations that an agency is violating section
508.
2. Other Government Certification Programs. Government
programs which test and certify software for federal use (such as the
JFMIP certification of financial management applications) should
incorporate section 508's accessibility requirements into their
certification processes [recommendation of the Equal Employment
Opportunity Commission].
3. Voluntary Advisory Committees of Persons with Disabilities.
Each cabinet level, large, and mid-sized agency that has not already
done so should form an intra-agency voluntary advisory committee of
persons with disabilities. See General Appendix A (Categories of
Agencies). Small and very small agencies are encouraged to form joint
inter-agency committees. These committees can assist agencies in
recognizing accessibility issues, finding cost-effective solutions, and
accomplishing testing. Participation by people with disabilities in all
such committees should be fully voluntary. The Equal Employment
Opportunity Commission and the Office of Personnel Management should
collaboratively publish guidance to assist agencies with setting up
these committees.
4. Community Partnerships. Each agency is encouraged to form
partnerships with disability rights groups. These partnerships can
assist agencies with recognizing accessibility issues, finding
solutions, and accomplishing testing.
Procurement Findings and Recommendations
Section 508's enforcement provisions apply only to EIT products
"procured" on or after August 7, 2000. The Access Board's
Standards to implement section 508 will be incorporated into the Federal
Acquisition Regulation (FAR). Most agencies are subject to the FAR. Some
others follow it voluntarily. The few remaining agencies, including the
U.S. Postal Service, will be required to modify their procurement
regulations to incorporate the 508 Standards.
Relatively few agencies currently incorporate accessibility
provisions into their EIT procurement contracts (several of the better
contract provisions have been incorporated into this Report to serve as
models for other agencies; see, e.g., The Department of
Education's contract language, attached as Procurement Appendix B). Even
fewer agencies test EIT products for accessibility prior to bid
acceptance. A great majority of agencies continue to address EIT
accessibility issues on an ad hoc basis.
The Department recommends agencies take the following steps to
improve their procurement policies and practices:
1. Specific Language for RFPs and Contracts. Each agency
should incorporate appropriate procurement language that specifically
addresses accessibility for persons with disabilities in all EIT RFP's
(requests for proposals) and contracts to be in compliance with the
Federal Acquisition Regulation or other applicable federal procurement
regulation.
2. Agencies Not Subject to the Federal Acquisition Regulation
(FAR). Although most agencies are covered by the FAR, any that is
not should consult with the Access Board without delay to ensure that
its procurement regulations are appropriately modified to incorporate
the Section 508 Standards when they are final.
3. Discontinue Ad Hoc Approach. Each agency that has not
already done so should develop systematic ways to ensure that it is
procuring accessible EIT products, rather than relying on an ad hoc
approach. This method will increase the interoperability of different
types of technology and is especially necessary as technology increases
in complexity. Each agency should review all of its procurement
practices and policies, formal and informal, to determine whether
accessibility issues are appropriately addressed.
Technology-Specific Findings and
Recommendations
Federal Agencies' Web Pages
Federal agencies' Internet and intranet sites contain some barriers
to access for people with disabilities. The most commonly encountered
barrier is the failure to provide appropriate and meaningful text
information for visual images ("alt text" for simple images
and icons and long descriptions for more complicated graphics). This
barrier, like others that are encountered less frequently, can be
eliminated quite easily with minimal design changes.
Part of the reason that agency Web pages are relatively easy for
people with disabilities to use is that most agencies have consciously
decided to make their pages readily usable by people who use older, less
expensive, and less sophisticated technology. Federal Internet pages
tend to be free from the "bells and whistles" that require
more particular attention to accessibility issues, such as multimedia
content or interactive features.
As agencies put more of their programs and services online, they must
remain vigilant to ensure they are not inadvertently creating barriers
for people with disabilities. Online forms and documents rendered
exclusively in Adobe's portable document format (pdf) or Microsoft's
PowerPoint format may raise particular concerns.
As most barriers on agency Web sites result from an inattention to
detail rather than an underlying difficulty with the design or
technology, agencies should invite people with disabilities to inform
them when they encounter barriers.
To address these issues and others detailed in the Report, the
Department recommends the following:
1. Testing Web Pages Before Posting. Each agency should
evaluate for accessibility all of its new Web pages before they are
posted. Existing Web pages should be tested as they are updated. Testing
should be done with text-only browsers and, where possible, with
assistive technology such as screen reading software to ensure that the
experience of users with disabilities is comparable to that of others.
2. Agency Web Guidelines. Each agency that has developed style
guidelines to maintain a consistent "look and feel" of its Web
pages should review those guidelines to ensure that they will maximize
the accessibility of the agency's Web pages.
3. The Government Printing Office (GPO). Many smaller agencies
rely on the GPO for their Web site design and maintenance. While section
508 does not apply to the GPO, the GPO should provide leadership to
ensure that all Web pages it develops or maintains are accessible.
4. Dedicated E-mail Addresses. Because most accessibility
problems on agency Web sites result from oversight or lack of awareness
of accessibility issues, rather than technical or design difficulty,
each agency should prominently post to its Internet pages an e-mail
address through which users with disabilities can inform the agency of
any accessibility barriers encountered. Each agency should be responsive
to any e-mails it receives regarding the accessibility of its Web site
to people with disabilities.
5. Accessibility Information Logo. The National Endowment for
the Arts, along with the Universal Access Working Group, GSA, and the
Access Board, should develop an easy-to-recognize accessibility
information logo (and alternative text label). Each agency should use
this logo (and text label) to link people with disabilities who use its
Web pages with appropriate accessibility instructions and information,
including an e-mail address to the agency's accessibility
point-of-contact.
6. Location of Accessibility Information. Where it makes sense
to do so, such as when placing a link to a text-only alternate Web site
or when posting the accessibility instruction logo and label, each
agency should place accessibility information in the uppermost left-hand
corner of its Web pages. This location will facilitate use of the
agency's Web pages by people who use screen readers, as it is the first
location from which a screen reader will read.
7. Document Formats. As agencies put more of their programs
and services online, each must remain vigilant to ensure it is not
inadvertently creating barriers for people with disabilities. Online
forms created using any of the various Web technologies pose significant
accessibility challenges to Web designers. Documents rendered
exclusively in Adobe's portable document format (pdf) or Microsoft's
PowerPoint formats may raise particular concerns. If any posted
documents or forms are less than fully accessible, each agency should
also post ASCII or accessible HTML versions of the same documents, where
possible. Where exclusive reliance on an inaccessible format is
unavoidable, each agency should provide contact information where users
with disabilities can request the underlying information in an
accessible format, where doing so would not impose an undue burden on
the agency or result in an fundamental alteration.
Software
Almost all software applications contained some barriers to some
people with disabilities. Most applications, however, provided a fair
degree of accessibility to most people with disabilities. Among the
communities most likely to face significant barriers are those who are
blind, those with low vision, and those with multiple disabilities.
A sizable majority of the software applications used most frequently
by agencies are commercial off-the-shelf (COTS) applications used
without agency modification. The most commonly encountered barriers in
COTS software fall into the categories of (1) documentation and support;(5)
and (2) programming.(6)
The Department recommends the following:
1. Training Needs Surveys. Each agency should develop and
distribute "training needs" surveys to all employees. These
surveys should explicitly address training needs for people with
disabilities, especially those who use assistive technology in
conjunction with mainstream software applications. EEOC should provide
guidance to agencies on this issue.
2. Appropriate, Periodic Training. Each agency should train
all IT personnel, procurement officials, "help desks" and
other support personnel, and users with disabilities, regarding basic
accessibility issues. To conserve resources, GSA and the Access Board,
in consultation with other key agencies and inter-agency groups, should
create training modules that can be shared among agencies. GSA and the
Access Board should also make available lists of appropriate training
vendors. Each agency should ensure that specialized training is
available for users with disabilities for all software packages for
which training is generally provided, including training provided by
third-parties on behalf of agencies.
3. Software Compatibility Testing Centers. As agencies update
and centralize their IT architecture, they should create software
compatibility testing centers at which software can be evaluated for
compatibility with existing agency platforms and with commonly used
assistive technologies. Larger agencies may wish to establish their own
compatibility testing centers. An interagency software compatibility
testing center should be established to assist smaller agencies, larger
agencies without testing centers, and private software manufacturers and
developers. Centers at Department of Defense, Department of Education,
the Social Security Administration, Department of Veterans' Affairs, and
GSA can serve as models.
4. Documentation (Instructions, Help Files, User Manuals, Etc.).
Many software applications have accessibility features of which most
users, trainers, 'help desk' personnel, and others are unaware. Other
software applications (such as word processors, Adobe Acrobat, etc.) can
be used to create information products. Knowledgeable users can use
these applications to create information products that are relatively
accessible. Other people may inadvertently use the same applications in
such a way that the information products they create are largely
inaccessible. Each agency should require its software vendors to include
clear documentation of the accessibility features and appropriate uses
of their products to maximize accessibility.
5. "COTS Software Accessibility Manuals". Because
many of the Federal Government's current software applications may
continue to be used for a long time, federal agencies must make the most
of the accessibility features built into currently-used software, rather
than rely exclusively on procurement of new accessible software. GSA and
the Access Board, in consultation with other key agencies and
inter-agency groups, should consult with software manufacturers and
should develop and distribute supplemental manuals for users of
commercial off-the-shelf (COTS) software applications. These manuals
should include clear instructions for maximizing the accessibility of
COTS applications currently used by federal agencies and for promoting
accessibility and minimizing barriers in the information products some
COTS applications (such as Adobe Acrobat) are used to produce. Specific
information, such as macros developed to provide shortcut keys where
none previously existed, should be incorporated into these manuals.
6. Government-Wide, Low-Cost Programming Solutions. GSA and
the Access Board, in consultation with other key agencies and
inter-agency groups, should contact manufacturers of COTS software to
determine whether software updates, containing programming
"fixes" of barriers identified in this Report, may be obtained
freely or purchased for a low fee and distributed throughout all federal
agencies. Each agency that has already developed programming solutions
to remove barriers to COTS applications should be encouraged to continue
this work and to share their results with all appropriate agencies.
Telecommunications
Telecommunications poses specific accessibility issues for almost
every community of persons with disabilities, including people who are
deaf or hard of hearing and those with speech impairments, people who
have difficulty pressing touch-tone buttons, persons with visual
impairments who cannot see visually displayed information such as
message waiting or caller ID indicators, and persons with cognitive
impairments or learning disabilities who have difficulty understanding
or remembering serial connection choices (press 1 for ___;
press 2 for ___; etc.).
Few agencies are fully utilizing the efficient, low-cost services
that are available to them, such as the Federal Information Relay
Service (FIRS)(which allows deaf and hard of hearing people to
communicate via telephone with people who do not have special equipment,
such as TTYs).(7) The lack of awareness
of such resources has a negative impact on federal employees and job
applicants with disabilities, as well as members of the public with
disabilities. Training is often all that is required to improve this
situation.
Few agencies provide equivalent direct-access TTY connections for
serial connection services, automated call sequencing connection
services, or other interactive telephone services. As these services can
be difficult or impossible to navigate using the Telephone Relay
Service, few agencies have automated telephone systems that can be used
at all by people who are deaf or hard of hearing. For minimal cost,
additional lines with text messaging modes can be installed. These
serial connection services and automated interactive telephone services
can be made generally accessible to a wide variety of people with
disabilities -- including people with cognitive impairments and learning
disabilities, mobility impairments affecting dexterity or speed, and
others -- simply by providing an operator.
Most agencies that provide employees with pagers have text pagers
with vibration signals; these pagers are accessible to people who are
deaf or hard of hearing.
Few agencies have begun using the wide variety of disability-friendly
telecommunications products that are now offered by mainstream
telecommunications companies.
In light of these findings and others discussed in the Report, the
Department recommends the following:
1. Training. Each agency should train all federal employees
who communicate by telephone with the public or with other employees on
how to use TTY's, the Telephone Relay Service (TRS), and the Federal
Information Relay Service (FIRS). GSA and the Access Board, in
consultation with the FCC, should develop a short, electronic training
module that can be made available through agency intranet sites at
minimal expense.
2. TTY's in Public Areas. Each agency should provide TTY's,
outlets, and shelves wherever the agency provides telephones for members
of the public.
3. TTY's in Call Centers. Each agency should install TTY lines
wherever it receives a large volume of incoming calls.
4. FIRS. GSA, in consultation with the FCC and other key
agencies and inter-agency groups, should explore upgrading the Federal
Information Relay Service (FIRS) to include video relay interpreting and
speech-to-speech relay services.
5. Operators. Each cabinet level, large, and mid-sized agency
should make operators available on its interactive automated telephone
services and should allow callers to connect with operators by pressing
"0" or by staying on the line. See General Appendix A
(Categories of Agencies). Small and very small agencies should explore
cost-sharing measures to provide operators for their interactive
telephone services.
6. Equivalent Interactive TTY Telephone Services. Each agency
should configure its interactive telephone systems to be compatible with
TTY's or should provide equivalent TTY interactive systems containing
the same functions and information (and updated as often). This goal can
be easily accomplished by adding a second telephone line with a TTY
message and TTY compatible features that are equivalent to those
provided on the interactive voice systems.
7. Equivalent TTY Toll-Free Information Services. Each agency
that provides toll-free information lines should ensure that those lines
support TTY use or the agency should maintain equivalent separate
toll-free TTY information systems that are staffed to be as responsive
as the standard toll-free information lines.
8. Computer-Based TTY Equivalency Systems. GSA and the Access
Board, in consultation with the FCC and other key agencies and
inter-agency groups, should explore purchasing a government-wide license
(or multiple licenses to offer to agencies) of ASCII/computer-based TTY
systems to ensure that all agencies' employees with networked computers
have TTY equivalency on their network with minimal per-employee costs.
Appropriate attention should be paid to factors such as computer network
security.
9. Voice Recognition Technology. GSA and the Access Board, in
consultation with the FCC and other key agencies and inter-agency
groups, should explore buying multiple licenses for voice recognition
technology to install on all agencies' interactive telephone systems.
10. 'Telecommunications Technology Assistance Center'. The
FCC, in consultation with GSA, the Access Board, and other key agencies
and inter-agency groups, should establish a telecommunications technical
assistance center. This Technical Assistance Center should assist
agencies in working with manufacturers for example, to reconfigure
telephone systems to send a "wait" signal to TTY users and
to take full advantage of advances in technology that are coming from
section 255 of the Telecom Act and section 508 of the Rehabilitation
Act.
Kiosks and Other Information
Transaction Machines
Few agencies currently use information kiosks, point-of-sale card
reading machines, electronic building directories, or other types of
'information transaction machines' or ITMs. Where they are used, some
ITMs can be made more accessible to people with mobility impairments,
such as those who use wheelchairs, simply by moving them to more
accessible locations. Other barriers, such as an ITM's failure to
provide an audio mode that can be used by people who are blind or who
have low vision, can be more properly addressed by manufacturers.
Because section 508 does not require agencies to retroactively remove
barriers (although agencies continue to have nondiscrimination and
reasonable accommodation obligations under sections 501 and 504 of the
Rehabilitation Act), agencies with inaccessible ITMs should ensure that
the programs or services for which nondisabled people use ITMs are
accessible to people with disabilities through alternate means.
In light of these findings and others identified in the Report, the
Department recommends the following:
1. Non-Agency-Owned ITMs. Each agency that has facilities or
property containing ITMs that are owned or controlled by other entities
(including private entities, other federal agencies, or others) should
notify them of any barriers to access in their ITMs and recommend that
such entities address accessibility issues on a specific time schedule.
2. Location of ITMs. Each agency that has ITMs should ensure
that its ITMs are located on accessible routes and are otherwise
accessible to people with disabilities such as those who use
wheelchairs.
3. Inaccessible ITMs. If an agency's existing ITM is
inaccessible or contains inaccessible features, the agency should ensure
that whatever information or services the agency provides on the ITM are
also available through an accessible and comparably convenient and
useful alternate means of access (e.g., automated telephone
service or through the Internet). The agency should provide appropriate
signage with full instructions regarding use of the accessible
alternative method of obtaining information or services.
4. Upgrading Existing ITMs. While section 508 does not
generally require retrofitting existing EIT, each agency that replaces
or updates an ITM's software or hardware should look for and take
advantage of easy opportunities to improve the ITM's accessibility.
5. Instructions. Many times, an ITM contains accessible
features, such as a volume control mechanism, but instructions on how to
use these features are missing or inadequate. Each agency that has an
ITM should survey the ITM and, if appropriate, contact the ITM vendor
for a full list of accessible features. The agency should provide clear
instructions in accessible formats.
Fax Machines, Copiers, Printers, and Other
IT Office Equipment
Most fax machines, copiers, printers, and other IT office equipment
contain barriers to access by people with disabilities. For instance,
most copiers give error messages on liquid crystal display (LCD) screens
that are generally inaccessible to people who are blind or who have low
vision. Many LCD screens are angled so that they are difficult or
impossible for people who use wheelchairs to read them.
Agencies generally found that when they used IT office equipment that
was attached to their computer network, many of these barriers were
eliminated. Most networked office equipment is designed to communicate
with the user while he or she is at his or her workstation. Desktop
computers can be easily equipped with assistive technology, such as
screen readers, for people with disabilities.
For these reasons, and others set forth in the Report, the Department
recommends the following:
1. Instructions. Many times, office machines contain
accessible features, such as a volume control mechanism on a fax
machine, but instructions on how to use these features are missing or
inadequate. Each agency should survey its fax machines, copiers, and
printers and, if appropriate, contact vendors for a full list of
accessible features. The agency should provide clear instructions in
accessible formats.
2. Networked IT Office Equipment. The extent to which copiers
and fax machines are accessible is greatly enhanced when the user can
send commands from an attached desktop computer terminal (such terminals
may be easily outfitted with the appropriate assistive technology to
meet an individual's needs). Each agency should, in appropriate
circumstances, seek out network solutions over stand-alone machines when
such solutions would provide a greater degree of accessibility for
employees and members of the public with disabilities.
3. Instructions for Alternatives. For inaccessible IT office
equipment that is available to the general public or a large number of
employees, each agency should ensure that accessible instructions are
available on how a person with a disability can obtain accessible
alternative services (such as where to seek assistance).
1. This document is available on the Department of
Justice's section 508 Web site (www.usdoj.gov/crt/508).
People with disabilities may request copies in Braille, large print, or
on computer disk by calling 1-800-514-0301 (voice) or 1-800-514-0383
(TTY).
2. Some people who are blind and people who are
deaf-blind use computer devices called "refreshable Braille
displays," which move pins up and down to form Braille letters. The
user "reads" the Braille letters across a line, then advances
the Braille display to the next line when ready.
3. Revitalization of the IDCC will enable it to
function as a central coordination point to eliminate duplication of
efforts and/or inconsistencies among agencies and inter-agency groups.
4. The Universal Access Working Group is part of
the Federal Information Services Applications Council of the National
Science and Technology Council's Committee on Computing, Information,
and Communications. It is coordinated through the Center for IT
Accommodation in the Office of Governmentwide Policy at the General
Services Administration.
5. Frequently encountered documentation and
support barriers include:
- A lack of clear instructions for keyboard functions (26%)
- Instructions for keyboard use not widely available (30%)
- Manuals and documentation are not provided in an electronic format
with text descriptions of charts, graphs, etc. (37%)
- Specialized training is not provided for users with disabilities
(53%)
6. Frequently encountered programming barriers
include:
- Lack of shortcut keys (37%)
- Poorly located field labels and descriptions (24%)
- Application won't allow users to override default fonts for
printing and text displays (28%)
- Application does not support "print to ASCII" (26%)
7. TTYs are text telephones. They are also called
'TDDs' or 'telecommunications devices for deaf persons. |
