Discussion:
Section 508 Auditing
Batusic, Mario
2018-10-10 06:19:50 UTC
Permalink
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?

2. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
Charles 'chaals' (McCathie) Nevile
2018-10-10 07:53:24 UTC
Permalink
On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario
Post by Batusic, Mario
Hello,
1. Do I understand right the updated Section 508 from the year
2017 that adopts WCAG 2.0 A and AA as the measure for the >accessibility
of websites and web apps?
I think that is the gist of it. You should check of course.
Post by Batusic, Mario
2. What is the way for a company to successfully show, that its
web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our
web app so that the evaluation results are confident and >accepted in
USA?
Somebody who undestands what they are doing. I don't know that there is a
list of "accepted suppliers", for certification, so you have to do your
due diligence yourself.

It would be good if there were people who clearly used an agreed
methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no
human help) is unlikely to do a good evaluation, and anyone who doesn't
use any tooling to look at your entire site might risk costing more money
than necessary.

There are a number of accessibility companies that are W3C members
partivipating in the work of *defining* WCAG. That doesn't prove they know
what they are doing and that they do it well, but it is certainly a good
sign, in my opinion. (There are also accessibility consultants who for one
reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals
Post by Batusic, Mario
Thanks a lot in advance.
Mario
Mario Batusic
Accessibility Engineer
www.fabasoft.com
Tel.: +43 732 606162-0
Twitter | Facebook | Google+ | YouTube
Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
Batusic, Mario
2018-10-10 08:17:02 UTC
Permalink
Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org; Batusic, Mario <***@fabasoft.com>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


2. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
Steve Green
2018-10-10 09:17:59 UTC
Permalink
I am not aware of any requirement for the auditor organization be a US company. We are a UK company and we have done Section 508 audits in the past, even when the testing requirements were different from WCAG.

A VPAT would be the obvious way to report the level of compliance. There isn’t a standard format for a VPAT but all the ones I have seen are largely similar. We took the best parts of everyone else’s to make ours – I’m happy to share it if that’s useful. There are lots on the web if you do a search, but be aware that VPATs are used for all sorts of ICT systems, not just web applications, so some will contain a lot of stuff you don’t need.

Steve Green
Managing Director
Test Partners Ltd


From: Batusic, Mario <***@fabasoft.com>
Sent: 10 October 2018 09:17
To: Charles 'chaals' (McCathie) Nevile <***@yandex.ru>; w3c-wai-***@w3.org
Subject: AW: Section 508 Auditing

Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


1. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
Charles 'chaals' (McCathie) Nevile
2018-10-10 10:43:20 UTC
Permalink
On Wed, 10 Oct 2018 11:17:59 +0200, Steve Green
Post by Steve Green
I am not aware of any requirement for the auditor organization be a US
company.
There is no requirement for an auditor - so no requirements on who the
auditor is...

cheers
Post by Steve Green
We are a UK company and we have done Section 508 audits in the past,
even when the testing requirements were different from WCAG.
A VPAT would be the obvious way to report the level of compliance. There
isn’t a standard format for a VPAT but all the ones I have seen >are
largely similar. We took the best parts of everyone else’s to make ours
– I’m happy to share it if that’s useful. There are lots on the web >if
you do a search, but be aware that VPATs are used for all sorts of ICT
systems, not just web applications, so some will contain a lot of >stuff
you don’t need.
Steve Green
Managing Director
Test Partners Ltd
09:17
Subject: AW: Section 508 Auditing
Hi Chaals,
Thanks a lot. That is not so nice from the US Gov that I have now to
gues, who knos his job and hwo does’nt.
Still an other question: Must the auditor organization be an US Company to be accepted?
Mario
Mittwoch, 10. Oktober 2018 09:53
Betreff: Re: Section 508 Auditing
On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario
Post by Batusic, Mario
Hello,
Do I understand right the updated Section 508 from the year 2017 that
adopts WCAG 2.0 A and AA as the measure for the >>accessibility of
websites and web apps?
I think that is the gist of it. You should check of course.
Post by Batusic, Mario
What is the way for a company to successfully show, that its web app is
accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our
web app so that the evaluation results are confident and >>accepted in
USA?
Somebody who undestands what they are doing. I don't know that there is
a list of "accepted suppliers", for certification, so you have to do
your due diligence yourself.
It would be good if there were people who clearly used an agreed
methodology and for whom you could get reviews.
As a quick start, anyone who uses an entirely automated process (with no
human help) is unlikely to do a good evaluation, and anyone who doesn't
use any tooling to >look at your entire site might risk costing more
money than necessary.
There are a number of accessibility companies that are W3C members
partivipating in the work of *defining* WCAG. That doesn't prove they
know what they are doing >and that they do it well, but it is certainly
a good sign, in my opinion. (There are also accessibility consultants
who for one reason or other do not do that but are good...)
Sorry the answer is so vague. That's how it is...
cheers
Chaals
Post by Batusic, Mario
Thanks a lot in advance.
Mario
Mario Batusic
Accessibility Engineer
www.fabasoft.com
Tel.: +43 732 606162-0
Twitter | Facebook | Google+ | YouTube
Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
--
Using Opera's mail client: http://www.opera.com/mail/
Kelly Childs
2018-10-10 12:43:42 UTC
Permalink
There are no "listed requirements." For our audit clients, we submit a
document stating what we believe qualifies us. It basically states what we
feel makes us an expert in accessibility standards including our
methodology and experience. I definitely recommend using someone who uses
actual disabled users to perform testing. OCR approves us as an auditor and
then we complete the audit. I recommend asking any company or individual
you look at to provide you with their qualifications and then decide which
one you feel is most qualified. If for some reason they are not qualified,
OCR would not approve them as an auditor.

Hope this helps!

On Wed, Oct 10, 2018 at 3:43 AM, Charles 'chaals' (McCathie) Nevile <
On Wed, 10 Oct 2018 11:17:59 +0200, Steve Green <
I am not aware of any requirement for the auditor organization be a US
company.
There is no requirement for an auditor - so no requirements on who the
auditor is...
cheers
We are a UK company and we have done Section 508 audits in the past, even
when the testing requirements were different from WCAG.
A VPAT would be the obvious way to report the level of compliance. There
isn’t a standard format for a VPAT but all the ones I have seen are largely
similar. We took the best parts of everyone else’s to make ours – I’m happy
to share it if that’s useful. There are lots on the web if you do a search,
but be aware that VPATs are used for all sorts of ICT systems, not just web
applications, so some will contain a lot of stuff you don’t need.
Steve Green
Managing Director
Test Partners Ltd
*Sent:* 10 October 2018 09:17
*Subject:* AW: Section 508 Auditing
Hi Chaals,
Thanks a lot. That is not so nice from the US Gov that I have now to gues,
who knos his job and hwo does’nt.
Still an other question: Must the auditor organization be an US Company to be accepted?
Mario
*Gesendet:* Mittwoch, 10. Oktober 2018 09:53
*Betreff:* Re: Section 508 Auditing
On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <
Hello,
1. Do I understand right the updated Section 508 from the year 2017
that adopts WCAG 2.0 A and AA as the measure for the accessibility of
websites and web apps?
I think that is the gist of it. You should check of course.
1. What is the way for a company to successfully show, that its web
app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit
our web app so that the evaluation results are confident and accepted in
USA?
Somebody who undestands what they are doing. I don't know that there is a
list of "accepted suppliers", for certification, so you have to do your due
diligence yourself.
It would be good if there were people who clearly used an agreed
methodology and for whom you could get reviews.
As a quick start, anyone who uses an entirely automated process (with no
human help) is unlikely to do a good evaluation, and anyone who doesn't use
any tooling to look at your entire site might risk costing more money than
necessary.
There are a number of accessibility companies that are W3C members
partivipating in the work of *defining* WCAG. That doesn't prove they know
what they are doing and that they do it well, but it is certainly a good
sign, in my opinion. (There are also accessibility consultants who for one
reason or other do not do that but are good...)
Sorry the answer is so vague. That's how it is...
cheers
Chaals
Thanks a lot in advance.
Mario
*Mario Batusic*
Accessibility Engineer
www.fabasoft.com
Tel.: +43 732 606162-0
Twitter <https://twitter.com/fabasoft> | Facebook
<https://www.facebook.com/fabasoft/> | Google+
<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube
<https://www.youtube.com/user/FabasoftCloud>
Fabasoft R&D GmbH, Honauerstraße 4
<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g>
4020 Linz, Österreich
<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g>
| Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
--
Using Opera's mail client: http://www.opera.com/mail/
--
*Kelly Childs*

*Director of Website Accessibility*

888.750.4556, option 7

[image: Visit School Webmasters Social Sites]
<http://www.schoolwebmasters.com/Contact_Us>
Batusic, Mario
2018-10-10 13:05:05 UTC
Permalink
Hi Steeve, Kelly, All

Thanks a lot for the Info you provided: it will help me to find the right auditor organization.

@Kelly: What does it mean “OCR” in this context? I know only Optical Character Recognition under this Abbr.

Thanks.

Mario

Von: Kelly Childs <***@schoolwebmasters.com>
Gesendet: Mittwoch, 10. Oktober 2018 14:44
An: Charles 'chaals' (McCathie) Nevile <***@yandex.ru>
Cc: w3c-wai-***@w3.org; Steve Green <***@testpartners.co.uk>
Betreff: Re: Section 508 Auditing

There are no "listed requirements." For our audit clients, we submit a document stating what we believe qualifies us. It basically states what we feel makes us an expert in accessibility standards including our methodology and experience. I definitely recommend using someone who uses actual disabled users to perform testing. OCR approves us as an auditor and then we complete the audit. I recommend asking any company or individual you look at to provide you with their qualifications and then decide which one you feel is most qualified. If for some reason they are not qualified, OCR would not approve them as an auditor.

Hope this helps!

On Wed, Oct 10, 2018 at 3:43 AM, Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>> wrote:
On Wed, 10 Oct 2018 11:17:59 +0200, Steve Green <***@testpartners.co.uk<mailto:***@testpartners.co.uk>> wrote:
I am not aware of any requirement for the auditor organization be a US company.

There is no requirement for an auditor - so no requirements on who the auditor is...

cheers

We are a UK company and we have done Section 508 audits in the past, even when the testing requirements were different from WCAG..

A VPAT would be the obvious way to report the level of compliance. There isn’t a standard format for a VPAT but all the ones I have seen are largely similar. We took the best parts of everyone else’s to make ours – I’m happy to share it if that’s useful. There are lots on the web if you do a search, but be aware that VPATs are used for all sorts of ICT systems, not just web applications, so some will contain a lot of stuff you don’t need.

Steve Green
Managing Director
Test Partners Ltd


From: Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Sent: 10 October 2018 09:17
To: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>; w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: AW: Section 508 Auditing

Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


1. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g>
4020 Linz, Österreich<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g> | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
--
Using Opera's mail client: http://www.opera.com/mail/
--
Kelly Childs
Director of Website Accessibility

888.750.4556, option 7

[Das Bild wurde vom Absender entfernt. Visit School Webmasters Social Sites]<http://www.schoolwebmasters.com/Contact_Us>
Kelly Childs
2018-10-10 13:15:16 UTC
Permalink
Sorry about that. I was referring to the Office of Civil Rights. Our audit
clients typically have requested an audit because they received a complaint
from the Office of Civil Rights in the US. For those who have not received
a complaint, we still provide them with the same information so they are
able to make an informed decision on their own.

Thanks!
Post by Batusic, Mario
Hi Steeve, Kelly, All
Thanks a lot for the Info you provided: it will help me to find the right
auditor organization.
@Kelly: What does it mean “OCR” in this context? I know only Optical
Character Recognition under this Abbr.
Thanks.
Mario
*Gesendet:* Mittwoch, 10. Oktober 2018 14:44
*Betreff:* Re: Section 508 Auditing
There are no "listed requirements." For our audit clients, we submit a
document stating what we believe qualifies us. It basically states what we
feel makes us an expert in accessibility standards including our
methodology and experience. I definitely recommend using someone who uses
actual disabled users to perform testing. OCR approves us as an auditor and
then we complete the audit. I recommend asking any company or individual
you look at to provide you with their qualifications and then decide which
one you feel is most qualified. If for some reason they are not qualified,
OCR would not approve them as an auditor.
Hope this helps!
On Wed, Oct 10, 2018 at 3:43 AM, Charles 'chaals' (McCathie) Nevile <
On Wed, 10 Oct 2018 11:17:59 +0200, Steve Green <
I am not aware of any requirement for the auditor organization be a US company.
There is no requirement for an auditor - so no requirements on who the auditor is...
cheers
We are a UK company and we have done Section 508 audits in the past, even
when the testing requirements were different from WCAG..
A VPAT would be the obvious way to report the level of compliance. There
isn’t a standard format for a VPAT but all the ones I have seen are largely
similar. We took the best parts of everyone else’s to make ours – I’m happy
to share it if that’s useful. There are lots on the web if you do a search,
but be aware that VPATs are used for all sorts of ICT systems, not just web
applications, so some will contain a lot of stuff you don’t need.
Steve Green
Managing Director
Test Partners Ltd
*Sent:* 10 October 2018 09:17
*Subject:* AW: Section 508 Auditing
Hi Chaals,
Thanks a lot. That is not so nice from the US Gov that I have now to gues,
who knos his job and hwo does’nt.
Still an other question: Must the auditor organization be an US Company to be accepted?
Mario
*Gesendet:* Mittwoch, 10. Oktober 2018 09:53
*Betreff:* Re: Section 508 Auditing
On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <
Hello,
1. Do I understand right the updated Section 508 from the year 2017
that adopts WCAG 2.0 A and AA as the measure for the accessibility of
websites and web apps?
I think that is the gist of it. You should check of course.
1. What is the way for a company to successfully show, that its web
app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit
our web app so that the evaluation results are confident and accepted in
USA?
Somebody who undestands what they are doing. I don't know that there is a
list of "accepted suppliers", for certification, so you have to do your due
diligence yourself.
It would be good if there were people who clearly used an agreed
methodology and for whom you could get reviews.
As a quick start, anyone who uses an entirely automated process (with no
human help) is unlikely to do a good evaluation, and anyone who doesn't use
any tooling to look at your entire site might risk costing more money than
necessary.
There are a number of accessibility companies that are W3C members
partivipating in the work of *defining* WCAG. That doesn't prove they know
what they are doing and that they do it well, but it is certainly a good
sign, in my opinion. (There are also accessibility consultants who for one
reason or other do not do that but are good...)
Sorry the answer is so vague. That's how it is...
cheers
Chaals
Thanks a lot in advance.
Mario
*Mario Batusic*
Accessibility Engineer
www.fabasoft.com
Tel.: +43 732 606162-0
Twitter <https://twitter.com/fabasoft> | Facebook
<https://www.facebook.com/fabasoft/> | Google+
<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube
<https://www.youtube.com/user/FabasoftCloud>
Fabasoft R&D GmbH, Honauerstraße 4
<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g>
4020 Linz, Österreich
<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g>
| Handelsgericht Linz, FN 190091x
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Social Sites] <http://www.schoolwebmasters.com/Contact_Us>
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<http://www.schoolwebmasters.com/Contact_Us>
Jonathan Avila
2018-10-10 14:06:51 UTC
Permalink
Ø Office of Civil Rights

And for clarification for those on the list that might not be familiar you are speaking about the Office of Civil Rights within the US Department of Education. There are offices of civil rights in different agencies such as Health and Human Services and the Department of Justice to name a few – there is no general Office of Civil Rights that resides at the department or agency level.

Jonathan

Jonathan Avila
Chief Accessibility Officer
Level Access
***@levelaccess.com<mailto:***@levelaccess.com>
703.637.8957 office

Visit us online:
Website<http://www.levelaccess.com/> | Twitter<https://twitter.com/LevelAccessA11y> | Facebook<https://www.facebook.com/LevelAccessA11y/> | LinkedIn<https://www.linkedin.com/company/level-access> | Blog<http://www.levelaccess.com/blog/>

Looking to boost your accessibility knowledge? Check out our free webinars!<https://www.levelaccess.com/compliance-resources/webinars/>

The information contained in this transmission may be attorney privileged and/or confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited.

From: Kelly Childs [mailto:***@schoolwebmasters.com]
Sent: Wednesday, October 10, 2018 9:15 AM
To: Batusic, Mario
Cc: Charles 'chaals' (McCathie) Nevile; w3c-wai-***@w3.org; Steve Green
Subject: Re: Section 508 Auditing

Sorry about that. I was referring to the Office of Civil Rights. Our audit clients typically have requested an audit because they received a complaint from the Office of Civil Rights in the US. For those who have not received a complaint, we still provide them with the same information so they are able to make an informed decision on their own.

Thanks!

On Wed, Oct 10, 2018 at 6:05 AM, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hi Steeve, Kelly, All

Thanks a lot for the Info you provided: it will help me to find the right auditor organization.

@Kelly: What does it mean “OCR” in this context? I know only Optical Character Recognition under this Abbr.

Thanks.

Mario

Von: Kelly Childs <***@schoolwebmasters.com<mailto:***@schoolwebmasters.com>>
Gesendet: Mittwoch, 10. Oktober 2018 14:44
An: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Cc: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Steve Green <***@testpartners.co.uk<mailto:***@testpartners.co.uk>>
Betreff: Re: Section 508 Auditing

There are no "listed requirements." For our audit clients, we submit a document stating what we believe qualifies us. It basically states what we feel makes us an expert in accessibility standards including our methodology and experience. I definitely recommend using someone who uses actual disabled users to perform testing. OCR approves us as an auditor and then we complete the audit. I recommend asking any company or individual you look at to provide you with their qualifications and then decide which one you feel is most qualified. If for some reason they are not qualified, OCR would not approve them as an auditor.

Hope this helps!

On Wed, Oct 10, 2018 at 3:43 AM, Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>> wrote:
On Wed, 10 Oct 2018 11:17:59 +0200, Steve Green <***@testpartners.co.uk<mailto:***@testpartners.co.uk>> wrote:
I am not aware of any requirement for the auditor organization be a US company.

There is no requirement for an auditor - so no requirements on who the auditor is...

cheers

We are a UK company and we have done Section 508 audits in the past, even when the testing requirements were different from WCAG..

A VPAT would be the obvious way to report the level of compliance. There isn’t a standard format for a VPAT but all the ones I have seen are largely similar. We took the best parts of everyone else’s to make ours – I’m happy to share it if that’s useful. There are lots on the web if you do a search, but be aware that VPATs are used for all sorts of ICT systems, not just web applications, so some will contain a lot of stuff you don’t need.

Steve Green
Managing Director
Test Partners Ltd


From: Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Sent: 10 October 2018 09:17
To: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>; w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: AW: Section 508 Auditing

Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


1. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g>
4020 Linz, Österreich<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g> | Handelsgericht Linz, FN 190091x
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Kelly Childs
Director of Website Accessibility

888.750.4556, option 7

[Das Bild wurde vom Absender entfernt. Visit School Webmasters Social Sites]<http://www.schoolwebmasters.com/Contact_Us>
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Director of Website Accessibility

888.750.4556, option 7

[Visit School Webmasters Social Sites]<http://www.schoolwebmasters.com/Contact_Us>
Peter Shikli
2018-10-10 16:59:13 UTC
Permalink
Mario,

OCR is the federal Office of Civil Rights.  They and the Department of
Justice (DoJ) are tasked with enforcing Section 508 of the
Rehabilitation Act.  OCR responds when the complaint is on the basis of
a class of people (the disabled), the most common situation, and DoJ
when the complaint is by an individual.  Both follow administrative law
against government agencies rather than civil law involving the private
sector.

The Office of Accessible Systems & Technology that I mentioned in my
previous post is under the OCR, and also under the federal Chief
Information Officer in some curious relationship.

Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
503-570-6831 - ***@access2online.com
Cell: 949-677-3705
FAX: 503-582-8337
www.access2online.com
Prison inmates helping websites become accessible
Post by Batusic, Mario
Hi Steeve, Kelly, All
Thanks a lot for the Info you provided: it will help me to find the
right auditor organization.
@Kelly: What does it mean “OCR” in this context? I know only Optical
Character Recognition under this Abbr.
Thanks.
Mario
*Gesendet:* Mittwoch, 10. Oktober 2018 14:44
*Betreff:* Re: Section 508 Auditing
There are no "listed requirements." For our audit clients, we submit a
document stating what we believe qualifies us. It basically states
what we feel makes us an expert in accessibility standards including
our methodology and experience. I definitely recommend using someone
who uses actual disabled users to perform testing. OCR approves us as
an auditor and then we complete the audit. I recommend asking any
company or individual you look at to provide you with their
qualifications and then decide which one you feel is most qualified.
If for some reason they are not qualified, OCR would not approve them
as an auditor.
Hope this helps!
On Wed, Oct 10, 2018 at 3:43 AM, Charles 'chaals' (McCathie) Nevile
On Wed, 10 Oct 2018 11:17:59 +0200, Steve Green
I am not aware of any requirement for the auditor organization
be a US company.
There is no requirement for an auditor - so no requirements on who
the auditor is...
cheers
We are a UK company and we have done Section 508 audits in the
past, even when the testing requirements were different from
WCAG..
A VPAT would be the obvious way to report the level of
compliance. There isn’t a standard format for a VPAT but all
the ones I have seen are largely similar. We took the best
parts of everyone else’s to make ours – I’m happy to share it
if that’s useful. There are lots on the web if you do a
search, but be aware that VPATs are used for all sorts of ICT
systems, not just web applications, so some will contain a lot
of stuff you don’t need.
Steve Green
Managing Director
Test Partners Ltd
*Sent:* 10 October 2018 09:17
*Subject:* AW: Section 508 Auditing
Hi Chaals,
Thanks a lot. That is not so nice from the US Gov that I have
now to gues, who knos his job and hwo does’nt.
Still an other question: Must the auditor organization be an
US Company to be accepted?
Mario
*Gesendet:* Mittwoch, 10. Oktober 2018 09:53
*Betreff:* Re: Section 508 Auditing
On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario
Hello,
1. Do I understand right the updated Section 508 from the
year 2017 that adopts WCAG 2.0 A and AA as the measure
for the accessibility of websites and web apps?
I think that is the gist of it. You should check of course.
2. What is the way for a company to successfully show,
that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who
should audit our web app so that the evaluation
results are confident and accepted in USA?
Somebody who undestands what they are doing. I don't know that
there is a list of "accepted suppliers", for certification, so
you have to do your due diligence yourself.
It would be good if there were people who clearly used an
agreed methodology and for whom you could get reviews.
As a quick start, anyone who uses an entirely automated
process (with no human help) is unlikely to do a good
evaluation, and anyone who doesn't use any tooling to look at
your entire site might risk costing more money than necessary.
There are a number of accessibility companies that are W3C
members partivipating in the work of *defining* WCAG. That
doesn't prove they know what they are doing and that they do
it well, but it is certainly a good sign, in my opinion.
(There are also accessibility consultants who for one reason
or other do not do that but are good...)
Sorry the answer is so vague. That's how it is...
cheers
Chaals
Thanks a lot in advance.
Mario
**
**
*Mario Batusic*
Accessibility Engineer
www.fabasoft.com <http://www.fabasoft.com/>
Tel.:              +43 732 606162-0
Twitter <https://twitter.com/fabasoft> | Facebook
<https://www.facebook.com/fabasoft/> | Google+
<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube
<https://www.youtube.com/user/FabasoftCloud>
Fabasoft R&D GmbH, Honauerstraße 4
<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g>
4020 Linz, Österreich
<https://maps.google.com/?q=Honauerstra%C3%9Fe+4+%0D%0A+4020+Linz,+%C3%96sterreich&entry=gmail&source=g>
| Handelsgericht Linz, FN 190091x
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/Director of Website Accessibility/
888.750.4556, option 7
Das Bild wurde vom Absender entfernt. Visit School Webmasters Social
Sites <http://www.schoolwebmasters.com/Contact_Us>
Bruce Bailey
2018-10-17 13:18:18 UTC
Permalink
Peter (et al.),

There is no “federal office of civil rights” but OCR exist in a few different agencies, like HHS and ED. But I am pretty sure you were referring to the one at DOJ:
http://www.justice.gov/crt

DOJ does not enforce Section 508. Federal agencies enforce 508 on themselves, as they do with other statutory requirements.

Your previous post<http://lists.w3.org/Archives/Public/w3c-wai-ig/2018OctDec/0014.html> correctly provides the best links to OAST, but please note that they are not “under the OCR” or the “federal CIO” but are part of the DHS Office of the (DHS) CIO. It is a pretty straightforward relationship IMHO.

Your previous post also asserted that “The Section 508 folks say they "pivoted" to WCAG 2.1 AA”. I am not aware of any “508 folks” saying anything like. We here at the Access Board have been trying to disabuse people of that idea. The Section 508 citation is to WCAG 2.0 Level AA, and we have no plans to update that citation.
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
***@access-board.gov<mailto:***@access-board.gov>

Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.


From: Peter Shikli <***@bizware.com>
Sent: Wednesday, October 10, 2018 12:59 PM
To: w3c-wai-***@w3.org
Subject: Re: AW: Section 508 Auditing

Mario,

OCR is the federal Office of Civil Rights. They and the Department of Justice (DoJ) are tasked with enforcing Section 508 of the Rehabilitation Act. OCR responds when the complaint is on the basis of a class of people (the disabled), the most common situation, and DoJ when the complaint is by an individual. Both follow administrative law against government agencies rather than civil law involving the private sector.

The Office of Accessible Systems & Technology that I mentioned in my previous post is under the OCR, and also under the federal Chief Information Officer in some curious relationship.

Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
503-570-6831 - ***@access2online.com<mailto:***@access2online.com>
Cell: 949-677-3705
FAX: 503-582-8337
www.access2online.com<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.access2online.com&data=02%7C01%7CBailey%40access-board.gov%7Ca7150c13891c4d14232e08d62ed26a84%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636747878614411884&sdata=CW99gdqm9wJLfrXGqTdiu1dVQB8ZEedPJ6o8yvz8Ijk%3D&reserved=0>
Prison inmates helping websites become accessible
Peter Shikli
2018-10-17 14:26:50 UTC
Permalink
Bruce,

Even after going through OAST's Trusted Tester Program myself, I'm still
unsure why we have an OAST running that instead of the US Access Board. 
Could you explain why the feds have two organizations that seem to
address Section 508 compliance?

Also, the reason I said OAST is under both OCR and the federal CIO is
because of the second sentence, "OAST is part of both the Office for
Civil Rights and Civil Liberties and the Office of Chief Information
Officer" at https://www.dhs.gov/office-accessible-systems-technology. 
Am I misreading that?

Cheers,
Peter
Post by Bruce Bailey
Peter (et al.),
There is no “federal office of civil rights” but OCR exist in a few
different agencies, like HHS and ED.  But I am pretty sure you were
http://www.justice.gov/crt
DOJ does not enforce Section 508.  Federal agencies enforce 508 on
themselves, as they do with other statutory requirements.
Your previous post
<http://lists.w3.org/Archives/Public/w3c-wai-ig/2018OctDec/0014.html>
correctly provides the best links to OAST, but please note that they
are not “under the OCR” or the “federal CIO” but are part of the DHS
Office of the (DHS) CIO.  It is a pretty straightforward relationship
IMHO.
Your previous post also asserted that “The Section 508 folks say they
"pivoted" to WCAG 2.1 AA”.  I am not aware of any “508 folks” saying
anything like.  We here at the Access Board have been trying to
disabuse people of that idea.  The Section 508 citation is to WCAG 2.0
Level AA, and we have no plans to update that citation.
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC  20004-1111
Thank you for your questions concerning section 508 of the
Rehabilitation Act Amendments of 1998.  Section 508 authorizes the
Access Board to provide technical assistance to individuals and
Federal departments and agencies concerning the requirements of this
section.  Technical assistance provided in this email is intended
solely as informal guidance; it is neither a determination of your
legal rights or responsibilities, nor a statement of the official
views of the U.S. Access Board or any other federal agency.  Any links
to non-federal websites are provided as a courtesy and do not
represent an endorsement of the linked information, products, or services.
*Sent:* Wednesday, October 10, 2018 12:59 PM
*Subject:* Re: AW: Section 508 Auditing
Mario,
OCR is the federal Office of Civil Rights.  They and the Department of
Justice (DoJ) are tasked with enforcing Section 508 of the
Rehabilitation Act.  OCR responds when the complaint is on the basis
of a class of people (the disabled), the most common situation, and
DoJ when the complaint is by an individual.  Both follow
administrative law against government agencies rather than civil law
involving the private sector.
The Office of Accessible Systems & Technology that I mentioned in my
previous post is under the OCR, and also under the federal Chief
Information Officer in some curious relationship.
Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
Cell: 949-677-3705
FAX: 503-582-8337
www.access2online.com
<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.access2online.com&data=02%7C01%7CBailey%40access-board.gov%7Ca7150c13891c4d14232e08d62ed26a84%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636747878614411884&sdata=CW99gdqm9wJLfrXGqTdiu1dVQB8ZEedPJ6o8yvz8Ijk%3D&reserved=0>
Prison inmates helping websites become accessible
Jonathan Avila
2018-10-17 14:34:04 UTC
Permalink
Ø Your previous post also asserted that “The Section 508 folks say they "pivoted" to WCAG 2.1 AA”. I am not aware of any “508 folks” saying anything like. We here at the Access Board have been trying to disabuse people of that idea. The Section 508 citation is to WCAG 2.0 Level AA, and we have no plans to update that citation.

They are under OCR within the Department of Homeland Security.

Jonathan

Jonathan Avila
Chief Accessibility Officer
Level Access
***@levelaccess.com<mailto:***@levelaccess.com>
703.637.8957 office

Visit us online:
Website<http://www.levelaccess.com/> | Twitter<https://twitter.com/LevelAccessA11y> | Facebook<https://www.facebook.com/LevelAccessA11y/> | LinkedIn<https://www.linkedin.com/company/level-access> | Blog<http://www.levelaccess.com/blog/>

Looking to boost your accessibility knowledge? Check out our free webinars!<https://www.levelaccess.com/compliance-resources/webinars/>

The information contained in this transmission may be attorney privileged and/or confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited.

From: Peter Shikli [mailto:***@bizware.com]
Sent: Wednesday, October 17, 2018 10:27 AM
To: Bruce Bailey; w3c-wai-***@w3.org; 508
Subject: Re: AW: Section 508 Auditing

Bruce,

Even after going through OAST's Trusted Tester Program myself, I'm still unsure why we have an OAST running that instead of the US Access Board. Could you explain why the feds have two organizations that seem to address Section 508 compliance?

Also, the reason I said OAST is under both OCR and the federal CIO is because of the second sentence, "OAST is part of both the Office for Civil Rights and Civil Liberties and the Office of Chief Information Officer" at https://www.dhs.gov/office-accessible-systems-technology. Am I misreading that?

Cheers,
Peter

Bruce Bailey wrote on 10/17/2018 6:18 AM:
Peter (et al.),

There is no “federal office of civil rights” but OCR exist in a few different agencies, like HHS and ED. But I am pretty sure you were referring to the one at DOJ:
http://www.justice.gov/crt

DOJ does not enforce Section 508. Federal agencies enforce 508 on themselves, as they do with other statutory requirements.

Your previous post<http://lists.w3.org/Archives/Public/w3c-wai-ig/2018OctDec/0014.html> correctly provides the best links to OAST, but please note that they are not “under the OCR” or the “federal CIO” but are part of the DHS Office of the (DHS) CIO. It is a pretty straightforward relationship IMHO.

Your previous post also asserted that “The Section 508 folks say they "pivoted" to WCAG 2.1 AA”. I am not aware of any “508 folks” saying anything like. We here at the Access Board have been trying to disabuse people of that idea. The Section 508 citation is to WCAG 2.0 Level AA, and we have no plans to update that citation.
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
***@access-board.gov<mailto:***@access-board.gov>

Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.


From: Peter Shikli <***@bizware.com><mailto:***@bizware.com>
Sent: Wednesday, October 10, 2018 12:59 PM
To: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: Re: AW: Section 508 Auditing

Mario,

OCR is the federal Office of Civil Rights. They and the Department of Justice (DoJ) are tasked with enforcing Section 508 of the Rehabilitation Act. OCR responds when the complaint is on the basis of a class of people (the disabled), the most common situation, and DoJ when the complaint is by an individual. Both follow administrative law against government agencies rather than civil law involving the private sector.

The Office of Accessible Systems & Technology that I mentioned in my previous post is under the OCR, and also under the federal Chief Information Officer in some curious relationship.

Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
503-570-6831 - ***@access2online.com<mailto:***@access2online.com>
Cell: 949-677-3705
FAX: 503-582-8337
www.access2online.com<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.access2online.com&data=02%7C01%7CBailey%40access-board.gov%7Ca7150c13891c4d14232e08d62ed26a84%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636747878614411884&sdata=CW99gdqm9wJLfrXGqTdiu1dVQB8ZEedPJ6o8yvz8Ijk%3D&reserved=0>
Prison inmates helping websites become accessible
Bruce Bailey
2018-10-17 16:42:10 UTC
Permalink
My apologies Peter, you are correct that OAST is part of both the DHS OCR and DHS OCIO. I also apologize for thinking that you meant the DOJ OCR and not the DHS OCR.

OAST is running Trusted Tester (1) because they have the resources (and the U.S. Access Board does not); and (2) because of how DHS came together, they needed something like Trusted Tester to bridge the differences between all the agencies that came together to form DHS. Bill Peterson who created OAST came from ED (where I first met him) and he provided the vision and leadership needed to open Trusted Tester up to a larger audience. As I understand it, the incremental cost of opening Trusted Tester was fairly marginal as compared to what needed to be done to address the 508 accessibility needs at DHS in any case.

My agency, the U.S. Access Board, writes accessibility regulations (and not just for 508) and we would have needed additional statutory authority (and funding) for something like Trusted Tester. DHS developed Trusted Tester because it met their internal agency business needs. Part of our statutory authority includes providing technical assistance (TA) with the standards we develop and promulgate. We provide that TA to all sources, not just federal employees. This is “why the feds have two organizations that seem to address Section 508 compliance”.

Please be assured that we (staff at the Access Board) consulted staff at OAST (and other Federal agencies) as we developed the Revised 508 Standards, since their real-world experience with the Original 508 Standards is so extensive. It is also the case that OAST is coordinating with us now to ensure that Trusted Tester (as it is being updated) is aligned with the Revised 508 Standards (which, of course, cite WCAG 2.0 Level AA). They have a recent press release about their progress:
http://www.dhs.gov/news/2018/10/01/accessibility-training-news

For an overview more information about the Access Board, and the training we can provide, please see:
http://www.access-board.gov/the-board
http://www.access-board.gov/training
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
202-272-0024 (voice)
202-272-0070 (TTY)
202-272-0081 (Fax)
***@access-board.gov<mailto:***@access-board.gov>

Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.


From: Peter Shikli <***@bizware.com>
Sent: Wednesday, October 17, 2018 10:27 AM
To: Bruce Bailey <***@Access-Board.gov>; w3c-wai-***@w3.org; 508 <***@Access-Board.gov>
Subject: Re: AW: Section 508 Auditing

Bruce,

Even after going through OAST's Trusted Tester Program myself, I'm still unsure why we have an OAST running that instead of the US Access Board. Could you explain why the feds have two organizations that seem to address Section 508 compliance?

Also, the reason I said OAST is under both OCR and the federal CIO is because of the second sentence, "OAST is part of both the Office for Civil Rights and Civil Liberties and the Office of Chief Information Officer" at https://www.dhs.gov/office-accessible-systems-technology<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.dhs.gov%2Foffice-accessible-systems-technology&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502440326&sdata=AZZxmmrn5kwqCRtbCYYotsktJun60UsxjNs8CbddirQ%3D&reserved=0>. Am I misreading that?

Cheers,
Peter

Bruce Bailey wrote on 10/17/2018 6:18 AM:
Peter (et al.),

There is no “federal office of civil rights” but OCR exist in a few different agencies, like HHS and ED. But I am pretty sure you were referring to the one at DOJ:
http://www.justice.gov/crt<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.justice.gov%2Fcrt&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502450330&sdata=A69Y%2BJda3Ry2m1XUNOceVZnVaO7CKUGg%2FYdTrl%2FdJHI%3D&reserved=0>

DOJ does not enforce Section 508. Federal agencies enforce 508 on themselves, as they do with other statutory requirements.

Your previous post<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Flists.w3.org%2FArchives%2FPublic%2Fw3c-wai-ig%2F2018OctDec%2F0014.html&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502450330&sdata=P5oWSKIoJeKHB09ifxZIFohpwVGeXc%2FRBc52FH59qHQ%3D&reserved=0> correctly provides the best links to OAST, but please note that they are not “under the OCR” or the “federal CIO” but are part of the DHS Office of the (DHS) CIO. It is a pretty straightforward relationship IMHO.

Your previous post also asserted that “The Section 508 folks say they "pivoted" to WCAG 2.1 AA”. I am not aware of any “508 folks” saying anything like. We here at the Access Board have been trying to disabuse people of that idea. The Section 508 citation is to WCAG 2.0 Level AA, and we have no plans to update that citation.
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
***@access-board.gov<mailto:***@access-board.gov>

Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.
Bruce Bailey
2018-10-17 18:19:24 UTC
Permalink
The Revised 508 Standards citations to WCAG are of the form:

shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0 (incorporated by reference, see 702.10.1).

I find five matches for that exact phrase from our page here:
http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines

For folks familiar with the WCAG conformance requirements, that’s the same as “WCAG 2.0 Level AA”.

For folks unfamiliar with WCAG, I will use the longer phrasing.



From: Starry Sky <***@live.com>
Sent: Wednesday, October 17, 2018 1:39 PM
To: Bruce Bailey <***@Access-Board.gov>; w3c-wai-***@w3.org
Subject: Section 508 Auditing - Level A vs Level AA


Hi Bruce - according to an exchange with a senior accessibility specialist at the Access Board, some 508 standards are only set at Level A and even then, only for "many" but not "all" 508 provisions:

"The WCAG 2.0 Level A and Level AA Success Criteria are applied to many of the provisions in the Revised 508 (2018) Standards. "

But per your reply, 2.0 Level AA is applied across all 508 standards. Or, did I read that wrong?

Can you please clarify if there are any 508 standards only set to Level A or not to WCAG 2.0 at all?

Skye

-------- Original Message --------
From: Bruce Bailey<mailto:***@Access-Board.gov>
Date: Wednesday, October 17, 2018 12:42 PM EDT
Subject: RE: AW: Section 508 Auditing
To: Peter Shikli<mailto:***@bizware.com>, W3c-wai-ig<mailto:w3c-wai-***@w3.org>
Cc: 508<mailto:***@Access-Board.gov>
My apologies Peter, you are correct that OAST is part of both the DHS OCR and DHS OCIO. I also apologize for thinking that you meant the DOJ OCR and not the DHS OCR.

OAST is running Trusted Tester (1) because they have the resources (and the U.S. Access Board does not); and (2) because of how DHS came together, they needed something like Trusted Tester to bridge the differences between all the agencies that came together to form DHS. Bill Peterson who created OAST came from ED (where I first met him) and he provided the vision and leadership needed to open Trusted Tester up to a larger audience. As I understand it, the incremental cost of opening Trusted Tester was fairly marginal as compared to what needed to be done to address the 508 accessibility needs at DHS in any case.

My agency, the U.S. Access Board, writes accessibility regulations (and not just for 508) and we would have needed additional statutory authority (and funding) for something like Trusted Tester. DHS developed Trusted Tester because it met their internal agency business needs. Part of our statutory authority includes providing technical assistance (TA) with the standards we develop and promulgate. We provide that TA to all sources, not just federal employees. This is “why the feds have two organizations that seem to address Section 508 compliance”.

Please be assured that we (staff at the Access Board) consulted staff at OAST (and other Federal agencies) as we developed the Revised 508 Standards, since their real-world experience with the Original 508 Standards is so extensive. It is also the case that OAST is coordinating with us now to ensure that Trusted Tester (as it is being updated) is aligned with the Revised 508 Standards (which, of course, cite WCAG 2.0 Level AA). They have a recent press release about their progress:
http://www.dhs.gov/news/2018/10/01/accessibility-training-news<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.dhs.gov%2Fnews%2F2018%2F10%2F01%2Faccessibility-training-news&data=02%7C01%7CBailey%40access-board.gov%7Cf47d9c7f9c3840cf25ce08d6345770a2%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753947496440398&sdata=1lDxvlUFuGsp2fMV2l4q2uUPiklnVlAPuGd2BjUXECw%3D&reserved=0>

For an overview more information about the Access Board, and the training we can provide, please see:
http://www.access-board.gov/the-board<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.access-board.gov%2Fthe-board&data=02%7C01%7CBailey%40access-board.gov%7Cf47d9c7f9c3840cf25ce08d6345770a2%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753947496450410&sdata=p9IRSyIUpbAsADP3zYCvNBn1nYvHit43fLnnVV%2F9Kqc%3D&reserved=0>
http://www.access-board.gov/training<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.access-board.gov%2Ftraining&data=02%7C01%7CBailey%40access-board.gov%7Cf47d9c7f9c3840cf25ce08d6345770a2%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753947496450410&sdata=HOEu%2F9IFeCmYfZJFkHGtPc5%2ByYYxVZajFsDp%2BqYZlIo%3D&reserved=0>
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
202-272-0024 (voice)
202-272-0070 (TTY)
202-272-0081 (Fax)
***@access-board.gov<mailto:***@access-board.gov>

Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.
Jonathan Avila
2018-10-17 23:00:41 UTC
Permalink
* Can you please clarify if there are any 508 standards only set to Level A or not to WCAG 2.0 at all?
Section 508 (Revised 2017) contains additional authoring tool, software, and hardware requirements that do not directly map to WCAG 2.0 A or AA.

Jonathan

Jonathan Avila, CPWA
Chief Accessibility Officer
Level Access
***@levelaccess.com
703.637.8957 office

Visit us online:
Website<http://www.levelaccess.com/> | Twitter<https://twitter.com/LevelAccessA11y> | Facebook<https://www.facebook.com/LevelAccessA11y/> | LinkedIn<https://www.linkedin.com/company/level-access> | Blog<http://www.levelaccess.com/blog/>

Looking to boost your accessibility knowledge? Check out our free webinars!<https://www.levelaccess.com/compliance-resources/webinars/>

The information contained in this transmission may be attorney privileged and/or confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited.

From: Starry Sky <***@live.com>
Sent: Wednesday, October 17, 2018 1:39 PM
To: Bruce Bailey <***@Access-Board.gov>; w3c-wai-***@w3.org
Subject: Section 508 Auditing - Level A vs Level AA


Hi Bruce - according to an exchange with a senior accessibility specialist at the Access Board, some 508 standards are only set at Level A and even then, only for "many" but not "all" 508 provisions:

"The WCAG 2.0 Level A and Level AA Success Criteria are applied to many of the provisions in the Revised 508 (2018) Standards. "

But per your reply, 2.0 Level AA is applied across all 508 standards. Or, did I read that wrong?

Can you please clarify if there are any 508 standards only set to Level A or not to WCAG 2.0 at all?

Skye

-------- Original Message --------
From: Bruce Bailey<mailto:***@Access-Board.gov>
Date: Wednesday, October 17, 2018 12:42 PM EDT
Subject: RE: AW: Section 508 Auditing
To: Peter Shikli<mailto:***@bizware.com>, W3c-wai-ig<mailto:w3c-wai-***@w3.org>
Cc: 508<mailto:***@Access-Board.gov>
My apologies Peter, you are correct that OAST is part of both the DHS OCR and DHS OCIO. I also apologize for thinking that you meant the DOJ OCR and not the DHS OCR.

OAST is running Trusted Tester (1) because they have the resources (and the U.S. Access Board does not); and (2) because of how DHS came together, they needed something like Trusted Tester to bridge the differences between all the agencies that came together to form DHS. Bill Peterson who created OAST came from ED (where I first met him) and he provided the vision and leadership needed to open Trusted Tester up to a larger audience. As I understand it, the incremental cost of opening Trusted Tester was fairly marginal as compared to what needed to be done to address the 508 accessibility needs at DHS in any case.

My agency, the U.S. Access Board, writes accessibility regulations (and not just for 508) and we would have needed additional statutory authority (and funding) for something like Trusted Tester. DHS developed Trusted Tester because it met their internal agency business needs. Part of our statutory authority includes providing technical assistance (TA) with the standards we develop and promulgate. We provide that TA to all sources, not just federal employees. This is “why the feds have two organizations that seem to address Section 508 compliance”.

Please be assured that we (staff at the Access Board) consulted staff at OAST (and other Federal agencies) as we developed the Revised 508 Standards, since their real-world experience with the Original 508 Standards is so extensive. It is also the case that OAST is coordinating with us now to ensure that Trusted Tester (as it is being updated) is aligned with the Revised 508 Standards (which, of course, cite WCAG 2.0 Level AA). They have a recent press release about their progress:
http://www.dhs.gov/news/2018/10/01/accessibility-training-news

For an overview more information about the Access Board, and the training we can provide, please see:
http://www.access-board.gov/the-board
http://www.access-board.gov/training
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
202-272-0024 (voice)
202-272-0070 (TTY)
202-272-0081 (Fax)
***@access-board.gov<mailto:***@access-board.gov>

Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.


From: Peter Shikli <***@bizware.com><mailto:***@bizware.com>
Sent: Wednesday, October 17, 2018 10:27 AM
To: Bruce Bailey <***@Access-Board.gov><mailto:***@Access-Board.gov>; w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; 508 <***@Access-Board.gov><mailto:***@Access-Board.gov>
Subject: Re: AW: Section 508 Auditing

Bruce,

Even after going through OAST's Trusted Tester Program myself, I'm still unsure why we have an OAST running that instead of the US Access Board. Could you explain why the feds have two organizations that seem to address Section 508 compliance?

Also, the reason I said OAST is under both OCR and the federal CIO is because of the second sentence, "OAST is part of both the Office for Civil Rights and Civil Liberties and the Office of Chief Information Officer" at https://www.dhs.gov/office-accessible-systems-technology<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.dhs.gov%2Foffice-accessible-systems-technology&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502440326&sdata=AZZxmmrn5kwqCRtbCYYotsktJun60UsxjNs8CbddirQ%3D&reserved=0>. Am I misreading that?

Cheers,
Peter


Bruce Bailey wrote on 10/17/2018 6:18 AM:
Peter (et al.),

There is no “federal office of civil rights” but OCR exist in a few different agencies, like HHS and ED. But I am pretty sure you were referring to the one at DOJ:
http://www.justice.gov/crt<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.justice.gov%2Fcrt&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502450330&sdata=A69Y%2BJda3Ry2m1XUNOceVZnVaO7CKUGg%2FYdTrl%2FdJHI%3D&reserved=0>

DOJ does not enforce Section 508. Federal agencies enforce 508 on themselves, as they do with other statutory requirements.

Your previous post<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Flists.w3.org%2FArchives%2FPublic%2Fw3c-wai-ig%2F2018OctDec%2F0014.html&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502450330&sdata=P5oWSKIoJeKHB09ifxZIFohpwVGeXc%2FRBc52FH59qHQ%3D&reserved=0> correctly provides the best links to OAST, but please note that they are not “under the OCR” or the “federal CIO” but are part of the DHS Office of the (DHS) CIO. It is a pretty straightforward relationship IMHO.

Your previous post also asserted that “The Section 508 folks say they "pivoted" to WCAG 2.1 AA”. I am not aware of any “508 folks” saying anything like. We here at the Access Board have been trying to disabuse people of that idea. The Section 508 citation is to WCAG 2.0 Level AA, and we have no plans to update that citation.
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
***@access-board.gov<mailto:***@access-board.gov>

Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.
Emily Ogle
2018-10-18 00:14:05 UTC
Permalink
Given the actual VPAT 2.0+ Section 508 completely absorbs WCAG 2.0, save for four exceptions: Multiple Ways, Bypass Blocks, Consistent Identification and Consistent Navigation. (Don’t quote me on that last two, as they might be wrong.) Section 508 chapters include hardware, software, and documentation considerations intended to fill the gaps where WCAG doesn’t address, such as table semantics, as an example. Programmatic determination is a frequently occurring term in chapter 5.

Authoring tools and accessibility features are both contained within chapter 5 of Section 508, but the ATAG does a better job of addressing authoring tools, imo, and should be the go-to when trying to completely inclusive. Same with UAAG: it is more detailed than the Section 508 line items.
Post by Bruce Bailey
Can you please clarify if there are any 508 standards only set to Level A or not to WCAG 2.0 at all?
Section 508 (Revised 2017) contains additional authoring tool, software, and hardware requirements that do not directly map to WCAG 2.0 A or AA.
Jonathan
Jonathan Avila, CPWA
Chief Accessibility Officer
Level Access
703.637.8957 office
Website | Twitter | Facebook | LinkedIn | Blog
Looking to boost your accessibility knowledge? Check out our free webinars!
The information contained in this transmission may be attorney privileged and/or confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited.
Sent: Wednesday, October 17, 2018 1:39 PM
Subject: Section 508 Auditing - Level A vs Level AA
"The WCAG 2.0 Level A and Level AA Success Criteria are applied to many of the provisions in the Revised 508 (2018) Standards. "
But per your reply, 2.0 Level AA is applied across all 508 standards. Or, did I read that wrong?
Can you please clarify if there are any 508 standards only set to Level A or not to WCAG 2.0 at all?
Skye
-------- Original Message --------
From: Bruce Bailey
Date: Wednesday, October 17, 2018 12:42 PM EDT
Subject: RE: AW: Section 508 Auditing
To: Peter Shikli, W3c-wai-ig
Cc: 508
My apologies Peter, you are correct that OAST is part of both the DHS OCR and DHS OCIO. I also apologize for thinking that you meant the DOJ OCR and not the DHS OCR.
OAST is running Trusted Tester (1) because they have the resources (and the U.S. Access Board does not); and (2) because of how DHS came together, they needed something like Trusted Tester to bridge the differences between all the agencies that came together to form DHS. Bill Peterson who created OAST came from ED (where I first met him) and he provided the vision and leadership needed to open Trusted Tester up to a larger audience. As I understand it, the incremental cost of opening Trusted Tester was fairly marginal as compared to what needed to be done to address the 508 accessibility needs at DHS in any case.
My agency, the U.S. Access Board, writes accessibility regulations (and not just for 508) and we would have needed additional statutory authority (and funding) for something like Trusted Tester. DHS developed Trusted Tester because it met their internal agency business needs. Part of our statutory authority includes providing technical assistance (TA) with the standards we develop and promulgate. We provide that TA to all sources, not just federal employees. This is “why the feds have two organizations that seem to address Section 508 compliance”.
http://www.dhs.gov/news/2018/10/01/accessibility-training-news
http://www.access-board.gov/the-board
http://www.access-board.gov/training
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
202-272-0024 (voice)
202-272-0070 (TTY)
202-272-0081 (Fax)
Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.
Sent: Wednesday, October 17, 2018 10:27 AM
Subject: Re: AW: Section 508 Auditing
Bruce,
Even after going through OAST's Trusted Tester Program myself, I'm still unsure why we have an OAST running that instead of the US Access Board. Could you explain why the feds have two organizations that seem to address Section 508 compliance?
Also, the reason I said OAST is under both OCR and the federal CIO is because of the second sentence, "OAST is part of both the Office for Civil Rights and Civil Liberties and the Office of Chief Information Officer" at https://www.dhs.gov/office-accessible-systems-technology. Am I misreading that?
Cheers,
Peter
Peter (et al.),
http://www.justice.gov/crt
DOJ does not enforce Section 508. Federal agencies enforce 508 on themselves, as they do with other statutory requirements.
Your previous post correctly provides the best links to OAST, but please note that they are not “under the OCR” or the “federal CIO” but are part of the DHS Office of the (DHS) CIO. It is a pretty straightforward relationship IMHO.
Your previous post also asserted that “The Section 508 folks say they "pivoted" to WCAG 2.1 AA”. I am not aware of any “508 folks” saying anything like. We here at the Access Board have been trying to disabuse people of that idea. The Section 508 citation is to WCAG 2..0 Level AA, and we have no plans to update that citation.
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998. Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section. Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency. Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.
Urban, Mark (CDC/OCOO/OCIO/ITSO)
2018-10-10 11:56:46 UTC
Permalink
Hi all,

For the record, with exceptions for countries with which there are legal restrictions (e.g. North Korea, etc.), there is no mandate for Federal agencies or their partners to only use US companies in 508 work.

508 includes some additional requirements beyond WCAG 2.0 for web-based software, documentation of accessibility features, support services, and authoring tools. So I also recommend a VPAT 2.0 or higher as the reporting mechanism.

Regards,
Mark D. Urban
CDC/ATSDR Section 508 Coordinator
Office of the Chief Information Officer (OCIO)
Office of the Chief Operating Officer (OCOO)
***@CDC.gov<mailto:***@CDC.gov> | 919-541-0562 office
[cid:***@01D39E67.CE8948C0]

From: Charles 'chaals' (McCathie) Nevile <***@yandex.ru>
Sent: Wednesday, October 10, 2018 6:43 AM
To: w3c-wai-***@w3.org; Steve Green <***@testpartners.co.uk>
Subject: Re: Section 508 Auditing

On Wed, 10 Oct 2018 11:17:59 +0200, Steve Green <***@testpartners.co.uk<mailto:***@testpartners.co.uk>> wrote:
I am not aware of any requirement for the auditor organization be a US company.

There is no requirement for an auditor - so no requirements on who the auditor is...

cheers

We are a UK company and we have done Section 508 audits in the past, even when the testing requirements were different from WCAG.

A VPAT would be the obvious way to report the level of compliance. There isn’t a standard format for a VPAT but all the ones I have seen are largely similar. We took the best parts of everyone else’s to make ours – I’m happy to share it if that’s useful. There are lots on the web if you do a search, but be aware that VPATs are used for all sorts of ICT systems, not just web applications, so some will contain a lot of stuff you don’t need.

Steve Green
Managing Director
Test Partners Ltd


From: Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Sent: 10 October 2018 09:17
To: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>; w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: AW: Section 508 Auditing

Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


1. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
--
Using Opera's mail client: http://www.opera.com/mail/
Jonathan Avila
2018-10-10 14:16:46 UTC
Permalink
Ø There isn’t a standard format for a VPAT but all the ones I have seen are largely similar.


ITI owns the copyright on the VPAT report format. This is the most common format used to create Accessibility Conformance Reports (ACRs). The format can be used for reporting by anyone as long as you stick to the requirements listed in the VPAT template format. The current version of VPAT2 is VPAT2.2

https://www.itic.org/policy/accessibility/vpat

Jonathan

Jonathan Avila
Chief Accessibility Officer
Level Access
***@levelaccess.com<mailto:***@levelaccess.com>
703.637.8957 office

Visit us online:
Website<http://www.levelaccess.com/> | Twitter<https://twitter.com/LevelAccessA11y> | Facebook<https://www.facebook.com/LevelAccessA11y/> | LinkedIn<https://www.linkedin.com/company/level-access> | Blog<http://www.levelaccess.com/blog/>

Looking to boost your accessibility knowledge? Check out our free webinars!<https://www.levelaccess.com/compliance-resources/webinars/>

The information contained in this transmission may be attorney privileged and/or confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited.

From: Steve Green [mailto:***@testpartners.co.uk]
Sent: Wednesday, October 10, 2018 5:18 AM
To: w3c-wai-***@w3.org
Subject: RE: Section 508 Auditing

I am not aware of any requirement for the auditor organization be a US company. We are a UK company and we have done Section 508 audits in the past, even when the testing requirements were different from WCAG.

A VPAT would be the obvious way to report the level of compliance. There isn’t a standard format for a VPAT but all the ones I have seen are largely similar. We took the best parts of everyone else’s to make ours – I’m happy to share it if that’s useful. There are lots on the web if you do a search, but be aware that VPATs are used for all sorts of ICT systems, not just web applications, so some will contain a lot of stuff you don’t need.

Steve Green
Managing Director
Test Partners Ltd


From: Batusic, Mario <***@fabasoft.com>
Sent: 10 October 2018 09:17
To: Charles 'chaals' (McCathie) Nevile <***@yandex.ru>; w3c-wai-***@w3.org
Subject: AW: Section 508 Auditing

Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


1. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
Williams, William R -FS
2018-10-10 18:28:13 UTC
Permalink
Although it’s probably just a simple oversight, comments are still displayed in VPAT2.2508 - July2018. Otherwise, these seem to be very useful documents.

[Forest Service Shield]

Bill Williams, Information Technology Specialist
Regional Web Manager

Forest Service
Pacific Southwest Region

p: 707-562-9005
c: 707-980-8351
***@fs.fed.us<mailto:***@fs.fed.us>

1323 Club Drive
Vallejo, CA 94590
www.fs.usda.gov/r5<https://www.fs.usda.gov/r5>
[USDA Logo]<http://usda.gov/>[Forest Service Twitter]<https://twitter.com/forestservice>[USDA Facebook]<https://www.facebook.com/pages/US-Forest-Service/1431984283714112>

Caring for the land and serving people






From: Jonathan Avila [mailto:***@levelaccess.com]
Sent: Wednesday, October 10, 2018 7:17 AM
To: Steve Green <***@testpartners.co.uk>; w3c-wai-***@w3.org
Subject: RE: Section 508 Auditing


Ø There isn’t a standard format for a VPAT but all the ones I have seen are largely similar.


ITI owns the copyright on the VPAT report format. This is the most common format used to create Accessibility Conformance Reports (ACRs). The format can be used for reporting by anyone as long as you stick to the requirements listed in the VPAT template format. The current version of VPAT2 is VPAT2.2

https://www.itic.org/policy/accessibility/vpat

Jonathan

Jonathan Avila
Chief Accessibility Officer
Level Access
***@levelaccess.com<mailto:***@levelaccess.com>
703.637.8957 office

Visit us online:
Website<http://www.levelaccess.com/> | Twitter<https://twitter.com/LevelAccessA11y> | Facebook<https://www.facebook.com/LevelAccessA11y/> | LinkedIn<https://www.linkedin.com/company/level-access> | Blog<http://www.levelaccess.com/blog/>

Looking to boost your accessibility knowledge? Check out our free webinars!<https://www.levelaccess.com/compliance-resources/webinars/>

The information contained in this transmission may be attorney privileged and/or confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited.

From: Steve Green [mailto:***@testpartners.co.uk]
Sent: Wednesday, October 10, 2018 5:18 AM
To: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: RE: Section 508 Auditing

I am not aware of any requirement for the auditor organization be a US company. We are a UK company and we have done Section 508 audits in the past, even when the testing requirements were different from WCAG.

A VPAT would be the obvious way to report the level of compliance. There isn’t a standard format for a VPAT but all the ones I have seen are largely similar. We took the best parts of everyone else’s to make ours – I’m happy to share it if that’s useful. There are lots on the web if you do a search, but be aware that VPATs are used for all sorts of ICT systems, not just web applications, so some will contain a lot of stuff you don’t need.

Steve Green
Managing Director
Test Partners Ltd


From: Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Sent: 10 October 2018 09:17
To: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>; w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: AW: Section 508 Auditing

Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


1. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/




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Batusic, Mario
2018-10-11 05:56:16 UTC
Permalink
Jonathan,

Thanks for your clarifications!

Ciao Mario

Von: Jonathan Avila <***@levelaccess.com>
Gesendet: Mittwoch, 10. Oktober 2018 16:17
An: Steve Green <***@testpartners.co.uk>; w3c-wai-***@w3.org
Betreff: RE: Section 508 Auditing


Ø There isn’t a standard format for a VPAT but all the ones I have seen are largely similar.


ITI owns the copyright on the VPAT report format. This is the most common format used to create Accessibility Conformance Reports (ACRs). The format can be used for reporting by anyone as long as you stick to the requirements listed in the VPAT template format. The current version of VPAT2 is VPAT2.2

https://www.itic.org/policy/accessibility/vpat

Jonathan

Jonathan Avila
Chief Accessibility Officer
Level Access
***@levelaccess.com<mailto:***@levelaccess.com>
703.637.8957 office

Visit us online:
Website<http://www.levelaccess.com/> | Twitter<https://twitter.com/LevelAccessA11y> | Facebook<https://www.facebook.com/LevelAccessA11y/> | LinkedIn<https://www.linkedin.com/company/level-access> | Blog<http://www.levelaccess.com/blog/>

Looking to boost your accessibility knowledge? Check out our free webinars!<https://www.levelaccess.com/compliance-resources/webinars/>

The information contained in this transmission may be attorney privileged and/or confidential information intended for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any use, dissemination, distribution or copying of this communication is strictly prohibited.

From: Steve Green [mailto:***@testpartners.co.uk]
Sent: Wednesday, October 10, 2018 5:18 AM
To: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: RE: Section 508 Auditing

I am not aware of any requirement for the auditor organization be a US company. We are a UK company and we have done Section 508 audits in the past, even when the testing requirements were different from WCAG.

A VPAT would be the obvious way to report the level of compliance. There isn’t a standard format for a VPAT but all the ones I have seen are largely similar. We took the best parts of everyone else’s to make ours – I’m happy to share it if that’s useful. There are lots on the web if you do a search, but be aware that VPATs are used for all sorts of ICT systems, not just web applications, so some will contain a lot of stuff you don’t need.

Steve Green
Managing Director
Test Partners Ltd


From: Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Sent: 10 October 2018 09:17
To: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>; w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: AW: Section 508 Auditing

Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


1. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
--
Using Opera's mail client: http://www.opera.com/mail/
Patrick H. Lauke
2018-10-13 22:05:46 UTC
Permalink
On 10/10/2018 10:17, Steve Green wrote:
[...]
Post by Steve Green
A VPAT would be the obvious way to report the level of compliance.
Just to be a pedant, VPAT - Voluntary Product Accessibility Template -
refers to the template used. The end result, once you fill in the
template, is an Accessibility Conformance Report. But yes, in common
parlance, these are still referred to as VPATs.

P
--
Patrick H. Lauke

www.splintered.co.uk | https://github.com/patrickhlauke
http://flickr.com/photos/redux/ | http://redux.deviantart.com
twitter: @patrick_h_lauke | skype: patrick_h_lauke
Peter Shikli
2018-10-10 16:27:00 UTC
Permalink
Mario,

1. The Section 508 folks say they "pivoted" to WCAG 2.1 AA but did not
switch over to it, yet I don't see any significant difference now.

2. There is no Section 508 certificate any more than a WCAG certificate
since both are subjective self assessments.  Since federal agencies who
are required to meet Section 508 needed an objective measure their
Office of Accessible Systems & Technology
<https://www.dhs.gov/office-accessible-systems-technology> established
the Trusted Tester Program <https://www.dhs.gov/trusted-tester>, an
intensive 6-month training program focused entirely on Section 508
testing methodology.  Graduates scoring at least 90% on a week-long
final become certified Trusted Testers.  An accessibility audit
performed by certified Trusted Testers is the most likely to be accepted
by a federal agency in the USA.

Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
503-570-6831 - ***@access2online.com
Cell: 949-677-3705
FAX: 503-582-8337
www.access2online.com
Prison inmates helping websites become accessible
Post by Batusic, Mario
Hello,
1.Do I understand right the updated Section 508 from the year 2017
that adopts WCAG 2.0 A and AA as the measure for the accessibility of
websites and web apps?
2.What is the way for a company to successfully show, that its web app
is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit
our web app so that the evaluation results are confident and accepted
in USA?
Thanks a lot in advance.
Mario
**
**
*Mario Batusic*
Accessibility Engineer
www.fabasoft.com <http://www.fabasoft.com/>
Tel.:              +43 732 606162-0
Twitter <https://twitter.com/fabasoft> | Facebook
<https://www.facebook.com/fabasoft/> | Google+
<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube
<https://www.youtube.com/user/FabasoftCloud>
Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
SALES, TERRY LYNN
2018-10-10 17:39:45 UTC
Permalink
Version 5 which reflects the recent updates has not been released for public consumption yet. The training for certification against the new process is due to begin in December for Web IT systems with Software to follow in the spring. The changes are significant enough to require recertification, the training and test are now online, and yes, the score to achieve certification has been a 90%. Trusted Tester results are accepted by all Department of Homeland Security components, and recognized by many others.

Terry Lynn Sales
Cargo Systems Program Office, Architecture and Engineering
Section 508 Certified Tester / CR Support Lead
Customs and Border Protection
Beauregard B-222-1
571-468-5271 desk
703-945-2777 gov't phone
703-915-2277 cell

From: Peter Shikli <***@bizware.com>
Sent: Wednesday, October 10, 2018 12:27 PM
To: w3c-wai-***@w3.org
Subject: Re: Section 508 Auditing

Mario,

1. The Section 508 folks say they "pivoted" to WCAG 2.1 AA but did not switch over to it, yet I don't see any significant difference now.

2. There is no Section 508 certificate any more than a WCAG certificate since both are subjective self assessments. Since federal agencies who are required to meet Section 508 needed an objective measure their Office of Accessible Systems & Technology<https://www.dhs.gov/office-accessible-systems-technology> established the Trusted Tester Program<https://www.dhs.gov/trusted-tester>, an intensive 6-month training program focused entirely on Section 508 testing methodology. Graduates scoring at least 90% on a week-long final become certified Trusted Testers. An accessibility audit performed by certified Trusted Testers is the most likely to be accepted by a federal agency in the USA.

Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
503-570-6831 - ***@access2online.com<mailto:***@access2online.com>
Cell: 949-677-3705
FAX: 503-582-8337
www.access2online.com<http://www.access2online.com>
Prison inmates helping websites become accessible

Batusic, Mario wrote on 10/9/2018 11:19 PM:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?

2. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


[cid:***@01D33D3F.50086DC0]

Twitter<https://twitter.com/fabasoft> | Facebook<https://www.facebook.com/fabasoft/> | Google+<https://plus.google.com/+FabasoftCloud?hl=de> | YouTube<https://www.youtube.com/user/FabasoftCloud>

Fabasoft R&D GmbH, Honauerstraße 4
4020 Linz, Österreich | Handelsgericht Linz, FN 190091x
Emily Ogle
2018-10-10 17:01:17 UTC
Permalink
What are the differences between VPAT 2.1 and 2.2...?
Post by Peter Shikli
Mario,
1. The Section 508 folks say they "pivoted" to WCAG 2.1 AA but did not switch over to it, yet I don't see any significant difference now.
2. There is no Section 508 certificate any more than a WCAG certificate since both are subjective self assessments. Since federal agencies who are required to meet Section 508 needed an objective measure their Office of Accessible Systems & Technology established the Trusted Tester Program, an intensive 6-month training program focused entirely on Section 508 testing methodology. Graduates scoring at least 90% on a week-long final become certified Trusted Testers. An accessibility audit performed by certified Trusted Testers is the most likely to be accepted by a federal agency in the USA.
Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
Cell: 949-677-3705
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Post by Batusic, Mario
Hello,
1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?
2. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?
Thanks a lot in advance.
Mario
Mario Batusic
Accessibility Engineer
www.fabasoft.com
Tel.: +43 732 606162-0
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Jonathan Avila
2018-10-12 21:08:40 UTC
Permalink
* What are the differences between VPAT 2.1 and 2.2...?

Primarily the VPAT 2.2 format splits out different templates for WCAG, Section 508 revised, European standards, etc.

There are also a few wording changes such as the change to “partially supports” from “supports with exceptions”.

Jonathan

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From: Emily Ogle <***@yahoo.com>
Sent: Wednesday, October 10, 2018 1:01 PM
To: Peter Shikli <***@bizware.com>
Cc: w3c-wai-***@w3.org
Subject: Re: Section 508 Auditing

What are the differences between VPAT 2.1 and 2.2...?

On Oct 10, 2018, at 11:27 AM, Peter Shikli <***@bizware.com<mailto:***@bizware.com>> wrote:
Mario,

1. The Section 508 folks say they "pivoted" to WCAG 2.1 AA but did not switch over to it, yet I don't see any significant difference now.

2. There is no Section 508 certificate any more than a WCAG certificate since both are subjective self assessments. Since federal agencies who are required to meet Section 508 needed an objective measure their Office of Accessible Systems & Technology<https://www.dhs.gov/office-accessible-systems-technology> established the Trusted Tester Program<https://www.dhs.gov/trusted-tester>, an intensive 6-month training program focused entirely on Section 508 testing methodology. Graduates scoring at least 90% on a week-long final become certified Trusted Testers. An accessibility audit performed by certified Trusted Testers is the most likely to be accepted by a federal agency in the USA.

Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
503-570-6831 - ***@access2online.com<mailto:***@access2online.com>
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FAX: 503-582-8337
www.access2online.com<http://www.access2online.com>
Prison inmates helping websites become accessible

Batusic, Mario wrote on 10/9/2018 11:19 PM:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?
2. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


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Batusic, Mario
2018-10-11 10:15:01 UTC
Permalink
Hi Peter, Margaret, All,

Thanks a lot for you wonderful explanations. It helps me a lot in making decisions and selecting right auditing organisation.

Mario

Von: Peter Shikli <***@bizware.com>
Gesendet: Mittwoch, 10. Oktober 2018 18:59
An: w3c-wai-***@w3.org
Betreff: Re: AW: Section 508 Auditing

Mario,

OCR is the federal Office of Civil Rights. They and the Department of Justice (DoJ) are tasked with enforcing Section 508 of the Rehabilitation Act. OCR responds when the complaint is on the basis of a class of people (the disabled), the most common situation, and DoJ when the complaint is by an individual. Both follow administrative law against government agencies rather than civil law involving the private sector.

The Office of Accessible Systems & Technology that I mentioned in my previous post is under the OCR, and also under the federal Chief Information Officer in some curious relationship.

Cheers,
Peter Shikli
Access2online
A Division of Bizware Online Applications, Inc.
29030 SW Town Center Loop East
Suite 202-187
Wilsonville, OR 97070
503-570-6831 - ***@access2online.com<mailto:***@access2online.com>
Cell: 949-677-3705
FAX: 503-582-8337
www.access2online.com<http://www.access2online.com>
Prison inmates helping websites become accessible

Batusic, Mario wrote on 10/10/2018 6:05 AM:
Hi Steeve, Kelly, All

Thanks a lot for the Info you provided: it will help me to find the right auditor organization.

@Kelly: What does it mean “OCR” in this context? I know only Optical Character Recognition under this Abbr.

Thanks.

Mario

Von: Kelly Childs <***@schoolwebmasters.com><mailto:***@schoolwebmasters.com>
Gesendet: Mittwoch, 10. Oktober 2018 14:44
An: Charles 'chaals' (McCathie) Nevile <***@yandex.ru><mailto:***@yandex.ru>
Cc: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Steve Green <***@testpartners.co.uk><mailto:***@testpartners.co.uk>
Betreff: Re: Section 508 Auditing

There are no "listed requirements." For our audit clients, we submit a document stating what we believe qualifies us. It basically states what we feel makes us an expert in accessibility standards including our methodology and experience. I definitely recommend using someone who uses actual disabled users to perform testing. OCR approves us as an auditor and then we complete the audit. I recommend asking any company or individual you look at to provide you with their qualifications and then decide which one you feel is most qualified. If for some reason they are not qualified, OCR would not approve them as an auditor.

Hope this helps!

On Wed, Oct 10, 2018 at 3:43 AM, Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>> wrote:
On Wed, 10 Oct 2018 11:17:59 +0200, Steve Green <***@testpartners.co.uk<mailto:***@testpartners.co.uk>> wrote:
I am not aware of any requirement for the auditor organization be a US company.

There is no requirement for an auditor - so no requirements on who the auditor is...

cheers

We are a UK company and we have done Section 508 audits in the past, even when the testing requirements were different from WCAG..

A VPAT would be the obvious way to report the level of compliance. There isn’t a standard format for a VPAT but all the ones I have seen are largely similar. We took the best parts of everyone else’s to make ours – I’m happy to share it if that’s useful. There are lots on the web if you do a search, but be aware that VPATs are used for all sorts of ICT systems, not just web applications, so some will contain a lot of stuff you don’t need.

Steve Green
Managing Director
Test Partners Ltd


From: Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Sent: 10 October 2018 09:17
To: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>; w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>
Subject: AW: Section 508 Auditing

Hi Chaals,

Thanks a lot. That is not so nice from the US Gov that I have now to gues, who knos his job and hwo does’nt.

Still an other question: Must the auditor organization be an US Company to be accepted?

Mario

Von: Charles 'chaals' (McCathie) Nevile <***@yandex.ru<mailto:***@yandex.ru>>
Gesendet: Mittwoch, 10. Oktober 2018 09:53
An: w3c-wai-***@w3.org<mailto:w3c-wai-***@w3.org>; Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>>
Betreff: Re: Section 508 Auditing

On Wed, 10 Oct 2018 08:19:50 +0200, Batusic, Mario <***@fabasoft.com<mailto:***@fabasoft.com>> wrote:
Hello,

I have two questions:

1. Do I understand right the updated Section 508 from the year 2017 that adopts WCAG 2.0 A and AA as the measure for the accessibility of websites and web apps?


I think that is the gist of it. You should check of course.


1. What is the way for a company to successfully show, that its web app is accessible according to Section 508?
I think there is no Sect508 certificate available? Who should audit our web app so that the evaluation results are confident and accepted in USA?

Somebody who undestands what they are doing. I don't know that there is a list of "accepted suppliers", for certification, so you have to do your due diligence yourself.

It would be good if there were people who clearly used an agreed methodology and for whom you could get reviews.

As a quick start, anyone who uses an entirely automated process (with no human help) is unlikely to do a good evaluation, and anyone who doesn't use any tooling to look at your entire site might risk costing more money than necessary.

There are a number of accessibility companies that are W3C members partivipating in the work of *defining* WCAG. That doesn't prove they know what they are doing and that they do it well, but it is certainly a good sign, in my opinion. (There are also accessibility consultants who for one reason or other do not do that but are good...)

Sorry the answer is so vague. That's how it is...

cheers

Chaals


Thanks a lot in advance.

Mario




Mario Batusic
Accessibility Engineer

www.fabasoft.com<http://www.fabasoft.com/>

Tel.: +43 732 606162-0
E-Mail: ***@fabasoft.com<mailto:***@fabasoft.com>


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