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Section 508: Your Questions Answered

"The responsibilities you have as an instructional designer will determine how much you are involved in making a course meet Section 508 standards. While meeting Section 508 requirements involves some additional work (relative to a course that does not meet Section 508 requirements), the good news is it does not have to change the look of your course drastically. So do not be afraid of working toward meeting Section 508 standards! It is not as bad as you think!"

Many e-Learning producers in the United States have heard of Section 508, but what is it? What standards does it require? Does it affect me and my organization (even if we are in Europe or Asia, producing e-Learning for use in the United States), and if so, how? Will meeting Section 508 standards change the entire look of my course? What do I need to know about Section 508 as an instructional designer, developer, or manager?

Many of us wonder the same things and ask the same questions. In this article I will address these questions, and more, as I share experiences from actual projects. Writers and speakers often use the term “accessibility” in the same breath as “Section 508.” Aren’t they really the same thing? Well, they’re close to each other in meaning. A course designer could pay attention to accessibility, and yet not meet the requirements of Section 508. However, a course that meets the requirements of Section 508 will certainly be accessible. Accessibility means that electronic information and technology do not rely on a single sense or ability. For example, a system that requires the use of a mouse to navigate would not be accessible to people with mobility impairments that prevent them from using a mouse. One must either implement an alternative way of navigation, or the system must support an assistive technology that aids the user in navigation. Information and technology that is not accessible makes it difficult, if not impossible, for people with disabilities to obtain and use information efficiently. Thus, we have Section 508.

What is Section 508?

Section 508 is part of the Rehabilitation Act of 1973, amended in 1998. Section 508 states that electronic and information technology must be made accessible to people with disabilities. This law is based on World Wide Web Consortium (W3C) priority 1 checkpoints. (See Sidebar 1.) Note that these priority 1 checkpoints are more detailed than Section 508, so you do not have to meet all checkpoints listed under priority 1 in order to comply with Section 508.

 

SIDEBAR 1 W3C Priority 1 Checklist (taken from the W3C Web site)

In General (Priority 1)

Yes No N/A

1.1 Provide a text equivalent for every non-text element (e.g., via “alt,” “longdesc,” or in element content). This includes: images, graphical representations of text, image map regions, short animations (e.g., animated GIFs), applets, ascii art, frames, scripts, inserted list bullets, sounds (played with or without user interaction), stand-alone audio files, synthesized speech, audio tracks of video, and video.

2.1 Ensure that all information conveyed with color is also available without color, for example from context or markup.

4.1 Clearly identify changes in the natural language of a document’s text and any text equivalents (e.g., captions) of non-text content.

6.1 Organize content logically using appropriate structural markup so the organization remains clear even when associated style sheets are turned off or are not supported.

7.1 Avoid causing the screen to flicker until user agents allow users to control it.

14.1 Use the clearest and simplest language appropriate for a site’s content.

And if you use images and image maps (Priority 1):

1.2 Provide redundant text links for each active region of an image map. [Priority 1 - if server-side image maps are used, Priority 2 - if client-side image maps are used. Redundant text links for client-side image maps are only required until user agents render text equivalents for the map links.]

1.5 Replace ASCII art with an image or explain it. [Priority 1 or Priority 2 depending on the importance of the information.]

9.1 Provide client-side image maps instead of server-side image maps, except where the regions cannot be defined with an available geometric shape.

And if you use tables (Priority 1):

5.1 For data tables, identify row and column headers.

5.2 For data tables that have two or more logical levels of row or column headers, use markups to associate data cells and header cells.

And if you use frames (Priority 1):

6.2 Ensure that descriptions and text alternatives for dynamic content are updated when the dynamic content changes.

12.1 Title each frame so that users can keep track of frames by title.

And if you use applets and scripts (Priority 1):

6.3 Ensure that pages are usable when scripts, applets, or other programmatic objects are turned off or not supported. If this is not possible, provide equivalent mechanisms on an alternative accessible page.

And if you use multimedia (Priority 1):

1.3 For each movie, provide an auditory description of the video track and synchronize it with the audio track.

1.4 For any time-based presentation (e.g., a movie, animation, or multimedia presentation), synchronize equivalent alternatives (e.g., captions or video descriptions) with the presentation.

And if all else fails (Priority 1):

11.4 If, after best efforts, you cannot create an accessible page, provide a link to an alternative page that uses W3C technologies, is accessible, has equivalent information, and is updated as often as the inaccessible (original) page.

 

Specifically, Section 508 requires that Federal employees who have disabilities have access to and use of any information and technology developed, procured, maintained, or used in Federal agencies. Additionally, Section 508 requires that people with disabilities, who are members of the public and are seeking information or services from Federal agencies, must have comparable access to and use of information or services provided by these Federal agencies. Federal agencies must consider Section 508 standards even if there are currently no users with disabilities in need of information and technology that meets Section 508 standards. However, if meeting Section 508 standards places an undue burden on an agency, the agency is not required to meet them.

Electronic and information technology includes all electronic and information technology for computing, storage, communication, presentation, control, production and duplication. It also includes computers, software, networks, peripherals, and other types of electronic office equipment. Section 508 applies to procurements made on or after June 25, 2001. Procurements before that date are not required to meet Section 508 standards. Section 508 does apply to e-Learning.

Does Section 508 impact me or my organization?

Federal departments and agencies (but not state agencies or the private sector) must meet Section 508 standards. There are some exceptions, however. For example, states receiving Federal funds under the Technology Related Assistance for Individuals with Disabilities Act of 1998 must comply with Section 508. In addition, some states may actually require state agencies to comply with Section 508.

Furthermore, many states have their own accessibility standards and these states may require their agencies to comply. Typically these state requirements are stricter than those of the Federal Government. For example, New York adopted accessibility requirements before the federal government.

Here is a quick check list to help you determine whether your organization needs to comply with Section 508:

  • You work for and develop material for a Federal agency.
  • Your organization develops material for a Federal agency.
  • You work for an agency and develop material for an agency that receives funds under the Technology Related Assistance for Individuals with Disabilities Act of 1998 (i.e. a State College).
  • Your organization develops material for a State agency that receives funds under the Technology Related Assistance for Individuals with Disabilities Act of 1998.
  • You work for a State Agency residing in a state that requires fulfillment of Section 508 Standards.
  • Your organization develops material for a State Agency residing in a state that mandates fulfillment of Section 508 requirements.

If you were able to check any one of the items above, your material must meet Section 508 standards.

How are instructional designers involved in meeting Section 508?

Traditionally, instructional designers analyzed the audience, content, learning environment and desired performance level, developed learning objectives, selected delivery methods, and served as evaluators or editors. Due to more demands placed on instructional designers, their responsibilities have often expanded to include traditional roles of developers, programmers, program managers, graphic designers, and others.

When discussing how instructional designers must meet Section 508 standards, I have chosen to focus on the more “traditional” instructional design responsibilities, rather than jobs such as development and programming. I have assumed a team approach to course development, where an instructional designer, a graphic designer, a developer, and a programmer are all on board working on the same project under the direction of a manager. Therefore, if you are the only person designing and developing courses, you may need to have a more in-depth knowledge of other sections of Section 508.

Sidebar 2 a list of 16 elements that, when implemented, will ensure that a course (be it Web-based, instructor-led, computer-based, etc.) satisfies Section 508’s requirements for electronic information. While it is important to be familiar with each of these elements, I will discuss the requirements as a team of instructional designers will typically encounter them when designing or converting courses. I will amplify some of the 16 elements.

 

SIDEBAR 2 16 elements or requirements of Section 508

Section 508 specifies sixteen requirements that, when followed, should make electronic information accessible by people with disabilities. While there are other requirements, the sixteen elements listed here are specific to electronic information.

  1. You must provide a text-equivalent for every non-text element. This is
  2. because a screen reader will convert all non-text elements to their alternative text. This means that any image, graphic, video clip, audio clip, etc. must have a text-equivalent. If a person is using a screen reader in order to access electronic information they are unable to access information presented in the non-text elements unless those elements are given a text-equivalent. There are particular ways in which to incorporate text alternatives into electronic information. These include “alt” tags, “spacer” tags, “longdesc” (long descriptions), d-tags, or the non-text element must be described in the content. “Alt tags” are typically no more than 10 words and are used only for images that do not require detailed explanations. When you need a more detailed explanation long descriptions (longdesc) or d-links (description links) may be used. The longdesc associates an image description with the code that places the image in the page, whereas the d-link simply places a link near the image. However, many assistive technologies do not support longdesc, so it is typically best to use d-links. Use “spacer” tags to tell assistive technologies that the image contains no important information, and then the image will be skipped over.
  3. You must provide synchronized text alternatives for any multimedia
  4. presentations. Multimedia includes two or more media (i.e. video with audio). For example, if a movie is delivered via Real One Player, that movie must have a text transcript for any audio presented in the movie and this text must synchronize with the video as the movie is played. In addition, a text description of the video must also be included. By providing a transcript of the audio and a description of the video, anyone who is blind or deaf will have access to the material.
  5. Design pages so that any and all information conveyed with color is
  6. also available without color. This means that color should only be an enhancement to the content, and should never be used to convey required information or any information related to the content. For example, never state, “Click the green button to continue.”
  7. Organize documents so that they are readable without needing a
  8. style sheet. This means that Cascading Style Sheets should be used to lay out the visual appearance of the user experience, but should not be necessary in order for a user to access the content. When in question, turn off the style sheets and make sure the information or the document is still comprehensible.
  9. Use redundant text links for all server-side image maps. You can
  10. recognize a server side image map by mousing over the image and seeing coordinates displayed. Basically, there is no way to make a server-side image map accessible, thus the requirement of equivalent text links. These text links would lead a user to the same image that they would see when clicking on the server-side image map.
  11. Use client-side image maps instead of server-side image maps. The
  12. only exception is when you cannot define the regions of the map with an available geometric shape. Client-side image maps either have “alt tags” attached to each active region or use redundant text links.
  13. Identify row and column headers for data tables. Assistive technologies
  14. convert tables to words and lines, reading a cell at a time from left to right, one row at a time. When a table is more complicated, designers are encouraged to write a summary of what the table presents. Embed this summary into a table using the summary attribute.
  15. Use markup to associate data cells and header cells for data tables
  16. that have two or more logical levels of row or column headers.
  17. Title frames with text that facilitates the purpose of the frame.
  18. Frame titles are important to people using screen readers. Titles such as “middle frame” or “top frame” are of little use to the person using the screen reader. Frame titles should be more specific as to the purpose of the frame such as “Navigation bar” or “Title frame.”
  19. Design pages so as not to cause the screen to flicker with a frequency
  20. between 2 cycles per second (Hz) and 55 cycles per second. Pages, or elements on pages, that flicker at these rates have a greater chance of causing optically-induced seizures. It is also important to consider the effect that moving text or animated gifs may have on individuals with disabilities. Some people are unable to follow moving text across a screen due to either visual or cognitive impairments.
  21. If you cannot comply with Section 508 standards in any other way,
  22. a text-only page may be provided that contains information or functionality equivalent to the non-text version. Use a text-only version as a last resort to make content accessible.
  23. If pages utilize scripting languages to display content, or to create
  24. interface elements, identify the information provided by the script with functional text so assistive technology can read it. Scripts, such as JavaScript pop-up menus, must be directly accessible by assistive technologies, or there must be an alternative method for accessing equivalent functionality.
  25. If an applet, plug-in, or other application is required by the client in
  26. order to view content, the page must provide a link to the plug-in or applet. Additionally, these elements must also comply with Section 508 standards. If, for example, a PowerPoint file is required as a download, an alternative means of accessing content provided in the PowerPoint is required (PowerPoint files are not directly accessible).
  27. Electronic forms to be completed online must allow people using
  28. assistive technologies to access the information, field elements, and functionality required to complete the form. The main concern, with respect to forms, is whether or not a person with a disability (specifically blind or visually impaired) is able to determine the purpose of an input element and interact with it. For example, if there is a text entry field, a person with a visual impairment must be able to determine that the field is for text entry and must also know what type of information they are required to input into the field.
  29. Provide a method that allows users to skip over repetitive navigation
  30. links. For a person using a screen reader, repetitive links can become quite annoying. If the same links are present on every page presented to the user, then the user has to listen to the entire list of links each time they access a new page. By providing an option to skip navigation links, users are able to move directly to the main content.
  31. When a timed response is required, the user needs to be alerted
  32. to the fact the response is timed and the user must be given sufficient time to indicate that more time is required.

 


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