Section 1. Introduction

1.1 Purpose

Section 508 requires that Federal departments and agencies developing, procuring, maintaining, or using electronic and information technology ensure that Federal employees and members of the public with disabilities have access to and use of information and data, comparable to that of Federal employees and members of the public without disabilities.

This document provides a technical framework for helping Technik staff ensure that the electronic and information technologies we develop, procure or maintain are accessible to individuals with disabilities, and that they comply with Section 508 requirements. The manual serves as a reference to the law and regulations and includes guideline and checklists to assist Technik staff in meeting their responsibilities under Section 508 of the Rehabilitation Act of 1973, 29 U.S.C. § 794d, as amended.

Section 2. Section 508: The Law

2.1 Background

Section 508 of the Rehabilitation Act Amendments of 1998, signed into law on August 7, 1998 (Public Law 105-220), as a part of the Workforce Investment Act of 1998, requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, they shall ensure that the electronic and information technology allows Federal employees with disabilities to have access to and use of information and data that is comparable to the access to and use of information and data by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency. Section 508 also requires that individuals with disabilities, who are members of the public seeking information or services from a Federal agency, have access to and use of information and data that is comparable to that provided to the public who are not individuals with disabilities, unless an undue burden would be imposed on the agency.

(Reference: Access Board’s Final Rule, “Electronic and Information Technology Accessibility Standards” at: http://www.access-board.gov/ sec508/standards.htm ).

Section 508 established an administrative complaint process, providing that “any individual with a disability may file a complaint alleging that a Federal department or agency fails to comply with subsection (a)(1) in providing electronic and information technology.” The law specified that complaints are to be filed with the Federal department or agency alleged to be in noncompliance, and that the Federal department or agency receiving the complaint shall apply the complaint procedures established under section 504 for resolving allegations of discrimination in a federally conducted program or activity. Individuals may also file a civil action against an agency.

By law, Section 508’s enforcement provisions apply only to the electronic and information technology procured on or after June 21, 2001. While Section 508’s enforcement mechanisms apply only to procurement, Section 504 of the Rehabilitation Act requires access to Federal programs for persons with disabilities, and both Sections 501 and 504 require accommodation of Federal employees with disabilities (sections 501 and 504). Therefore, Section 508 cannot be used by Federal departments and agencies to avoid responsibilities under Sections 501 and 504 to provide equivalent facilitation or alternative means of access to information for employees or members of the public with disabilities. Section 508 provides specific standards as measures for Federal departments and agencies, but Federal departments and agencies still are required, under Section 504, to provide access to information and programs for persons with disabilities, even in those circumstances where EIT is not commercially available. If an undue burden claim prevents the procurement of EIT that is accessible, agencies still must provide alternative means for access.

2.2 Definition of Electronic and Information Technology (EIT).

(Reference: http://www.access-board.gov/ sec508/standards.htm )

In the standards published by the Access Board on electronic and information technology, the definition of EIT includes “information technology and any equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, telecommunications products (such as telephones), information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information.

The Access Board defines “information technology” as “any equipment or interconnected system or subsystem of equipment, which is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. The term information technology includes computers, ancillary equipment, software, hardware and similar procedures, services (including support services), and related resources.”

2.3 Electronic and Information Technology Accessibility Standards (Technical Standards)

Section 508 required the Access Board to develop accessibility standards for electronic and information technology (EIT). The final “Electronic and Information Technology Accessibility Standards (36 CFR Part 1194)” were published in the Federal Register on December 21, 2000.

The EIT accessibility standards published by the Access Board include technical provisions for different types of EIT technologies and also include performance-based requirements that deal with the functional capabilities of EIT.

The technical provisions include:

(1) requirements specific to each type of technology (Subpart B of the Access Board’s standards);

(2) functional performance criteria relating to the functional capabilities of covered technologies (Subpart C); and

(3) requirements for information, documentation, and support (Subpart D).

Subpart B: The technology-specific provisions address the following areas:

• · Software applications and operating systems (1194.21);
• · Web-based information or applications (1194.22);
• · Telecommunications products (1194.23);
• · Video or multi-media products (1194.24);
• · Self contained, closed products such as office equipment and kiosks (1194.25); and
• · Desktop and notebook computers (1194.26).

Subpart C: While the technology-specific provisions in Subpart B of the Access Board’s standards provide the standards for each specific category of product, the functional performance criteria in Subpart C should be used in evaluating whether the product meets Section 508 requirements overall, and also should be used for evaluating technologies or components where no specific requirement is found in the technology categories in Subpart B. These functional criteria were included to assure that the components of electronic and information technologies — even when individually accessible — still work together to create an accessible product. The functional criteria address the operation of the product including input and control functions, the operation and access to visual and audible information. These criteria support the ability of people with sensory or physical disabilities to locate, identify, and operate input, control and mechanical functions and to access the information provided, including text, static or dynamic images, icons, labels, sounds or incidental operating cues. For example, one provision requires that at least one mode of operation and information retrieval should be provided that does not require user vision, or that it provides support for assistive technology used by people who are blind or visually impaired. Another provision requires that at least one mode of operation and information retrieval be provided that does not require visual acuity greater than 20/70.

Subpart D: Subpart D deals with access to all information, documentation, and support provided to end users (employees) of covered technologies. At the USDA, this should be considered to include user guides, installation guides for end-user installable devices, and customer support and technical support communications. Subpart D requires that such information must be available in alternate formats upon request at no additional charge. Alternate formats or methods of communication can include Braille, cassette recordings, large print, electronic text, Internet postings, tele-typewriter for the deaf (TTY) access, and captioning and audio description for video materials.

Section 3. Application Accessibility Guidelines and Testing Procedures.

In the course of testing applications for accessibility, it is useful to have operational guidance for testing. The purpose is to provide testers with specific methods to use for testing and to show testers what they should be looking for to meet Section 508 requirements. Many current tools (Infocus, Bobby, etc.) really only apply to web pages and web applications. Testers and evaluators often feel, mistakenly, that Section 508 compliance testing has to be much more demanding and time consuming (and complicated) than it really turns out to be. The testing strategy proposed below is intended to serve as a working approach to evaluate accessibility against Section 508 standards without requiring a technical background in accessibility or assistive technology.

Hopefully, the approach discussed here should expedite applications testing and review and, at the same time, provide more realistic assessments of the accessibility of the application, and should be helpful in pointing out problem areas. At the same time, this testing strategy focuses directly on Section 508 compliance elements, as publicly available from the Access Board and in this document.

Introduction. This section describes specific techniques for evaluating whether software applications meet Section 508 requirements. For reference, see the

Access Board’s web site:

http://www.access-board.gov/ sec508/508standards.htm , then click the link for “Text”

By including testing with assistive technology software, the testing described here will also help to evaluate whether the software application is usable by persons with disabilities.

Summary

The techniques are:

• Run the application.
• Put the mouse aside and do not use it during any of the testing.
• Use the keyboard alone to navigate through the entire application and note where this does not work.
• With every navigation keystroke, watch the screen to ensure that there is a visible focal point that moves with each navigation keystroke, moving among all the pieces of information on the screen, and note where this does not work.
• Check to make sure that accessibility aids (e.g., “StickyKeys” and menu font enlargement) still work when the application is running, and note if this does not work.
• Test the application with a screen reading program to ensure that the application provides sufficient information to the screen reading program to be usable, and note where there are usability problems.

In the material that follows, this short summary is explained in more detail. The techniques described are simple to use, and produce results that are consistent with repetitive testing by any tester. In other words, the results are not subjective and the testing and its results may be easily replicated by anyone.

The approach described here does not require special software (except for the assistive technology testing), or specialized skill on the part of the evaluator. When combined with testing of software applications with assistive technologies as a part of the testing procedure, the testing strategy can predict, with nearly 100% accuracy, the usability of the software application by persons with disabilities. In addition, the testing results that the tester can document when following this procedure can serve as a comprehensive description of what exact changes must be made to software in order to make it accessible, as well as compliant with Section 508.

General testing requirements

Testing should be performed on an IBM-compatible personal computer with at least 64MB RAM (128MB or more preferred), a working sound card with connected speakers or headset, a mouse, and VGA display adapter and color monitor with display settings at 800×600 resolution and 256 colors. Windows 95, 98, Millenium Edition, NT4, or Windows 2000 Workstation, or Windows XP operating system should be installed. Computers or applications that run only on Macintosh OS, Unix OS, or operating systems other than those listed above will generally fail one or more of the Section 508 criteria and consequently fail core criteria for testing and cannot benefit from the following testing approach.

How to set up the display for testing. To set display settings in preparation for testing, select the START menu, select SETTINGS, select CONTROL PANEL, select DISPLAY, select the SETTINGS tab, set “Desktop Area” to 800 x 600, if it not already; then change the COLOR PALETTE to 256 colors, then select APPLY.

Testing with Assistive Technology

To fully test the usability of the application with assistive technology, we recommend undertaking the following tests using a screen reading program, either concurrently with the testing protocol described below (recommended), or as a separate step, duplicating the entire testing protocol. A demonstration version of the JAWS screen reading program is available from the Freedom Scientific web site, and it may be used to test the application for compatibility with, and usability with a screen reading program. The current location for a demonstration version is:

http://www.freedomscientific. com/fs_downloads/jaws_form.asp

Documentation is also available on the Freedom Scientific web site. The current location is:

http://www.freedomscientific. com/fs_support/doc_screenreaders.asp

For an assessment of usability of the application with the screen reading program, specialized knowledge of the screen reading program is not required. It is sufficient to simply launch the screen reading program, and then observe whether or not the screen reading program speaks every visually evident focal point as the tester uses the keyboard to navigate through the program. In addition:

• If a focal point is logically tied to a prompt (for example, if the focal point lands in an edit field with a prompt to the left of the edit field, or a radio button with a description above the radio button), and JAWS fails to read the prompt upon movement into that edit field or other control, that component in the application fails the assistive technology test.
• If the sighted tester cannot use the keyboard to navigate to areas on the screen where information is presented that the sighted tester looks at or observes for guidance in using the program, and if those areas of the screen are not spoken by JAWS in logical order as the tester uses the keyboard to navigate across the application, then that component fails the assistive technology test.

How to test the application.

The purpose of this test is to determine the compliance of the application with Section 508 requirements, and to develop complete responses to the USDA Section 508 Evaluation Checklist (See Appendix I). In undertaking this testing, there are three stringent requirements:

(1) NO USE OF THE MOUSE. The mouse should be set aside and not used at any time for any part of the keyboard, focus, and assistive technology tests of the application. For these tests, the keyboard can be the only means of navigation. If a component cannot be used without a mouse, or something cannot be done with the keyboard alone, that component fails one of the core Section 508 requirements, and testing need not continue further with that component. It does not matter whether or not the remaining application is fully keyboard-enabled, if the gateway to the remaining application can only be launched by mouse action, the application fails the “keyboard” test, and testing must be discontinued. The mouse will need to be used, however, to switch applications in the StickyKeys test, and may be used to in preparatory steps outside of the actual keyboard, focus, and assistive technology tests.

(2) FOCAL POINT MUST BE CAREFULLY MONITORED. Careful visual observation of the “focal point” is one of the central requirements of this test. The “focal point” is typically indicated by an on-screen highlight, color change, dotted outline, underline, change in cursor, or other physical change on the screen. This focal point must move among all interactive elements of the screen. In other words, if there are parts of the screen or application that provide information but cannot be “focused upon” under keyboard control, then that component of the application fails the “focus” test, and this should be noted. Nevertheless, further testing can continue.

(3) TESTING REQUIRES GOOD VISUAL ACUITY. Because the visual observation of the effect of keyboard navigation on the application — both for what IS focusable as well as for what is NOT focusable — is so central to the Section 508 testing, the testing must be conducted by a tester with good visual acuity. While blind and low vision testers have a useful role to play in testing the accessibility of applications, it is critically important that a fully sighted tester document what is physically displayed but is NOT accessible, in order to evaluate the “focus” requirement. Because of limitations in the actual application being tested, a blind tester will be unable to properly evaluate limitations in the application’s “focus” requirement.

Testing Protocol

The testing protocol is based on the Section 1194.21 Software Applications and Operating Systems standards, of Section 508. In this protocol, the word “component” will be used to indicate the part of the application that you currently observe at any moment on-screen, and may be further broken down into smaller units, such as on-screen controls (edit boxes, radio buttons, list boxes, etc.). When a component fails one of the tests below, the “Comments” section of the corresponding element in the Section 508 Evaluation Checklist should briefly describe the component and how it failed. For the sake of documenting the problem for internal developers who might be in a position to fix the failure, specific details (such as a description of on-screen controls) should be provided for further use by developers.

The “Software Applications and Operating Systems” evaluation checklist includes twelve elements, designated alphabetically, from “A” to “L,” corresponding directly with the “A” through “L” elements in the Section 508 standards, described at 36 CFR Part 1194, Subpart B — Technical Standards § 1194.21, Software applications and operating systems.

For the purpose of testing, elements A and C and D are combined, since they are tightly interrelated: Keyboard navigation (“element A”) changes the focal point (“element C”). Changes in focal point are the triggers for at least two major categories of assistive technologies — screen reading and screen enlargement. If a screen reading program is used as the basis for testing element D, it is usually efficient to test all three elements concurrently (keyboard use, focus, and assistive technology as represented by a screen reading program).

ELEMENT A (Keyboard): “When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.”

ELEMENT C (Focus): “A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes. The focus shall be programmatically exposed so that Assistive Technology can track focus and focus changes.”

ELEMENT D (Information available to Assistive Technology): “Sufficient information about a user interface element including the identity, operation and state of the element shall be available to Assistive Technology. When an image represents a program element, the information conveyed by the image must also be available in text.”

ACTION STEPS:

Keyboard test (element A):

Navigate, using the keyboard alone, through all of the components, dialogs, menus, and other interface elements to determine whether each of the interface elements is fully usable with the keyboard alone. Do not use the mouse during any part of the test, at any time. Test all of the typical navigation approaches including:

• Use the TAB key to navigate through sequentially through all of the elements of dialog boxes, forms, fields, and many other types of application interfaces. Use SHIFT + TAB to navigate in reverse through these same elements.
• Use DOWN ARROW key to navigate through lists or list boxes, or ALT + DOWN ARROW to open a combo box or list box, then DOWN ARROW to navigate, and ESC to close.
• Use ALT + a letter to activate an element that is marked with an underline under the “accelerator letter.”
• If the application uses a menu bar, press the ALT key by itself, and then use the right arrow key to navigate across menu items. Then in any given menu, navigate downward to observe whether a menu opens beneath the menu keyword. If the ALT key does not place focus on the menu, or (once that focus is visible) if the right and left and down and up cursor keys do not open up the menu, this test fails.
• When entering information into edit fields, the RIGHT or LEFT ARROW keys should navigate across existing text, and holding the DELETE and BACKSPACE keys should delete text.
• When entering information into edit fields, move to the beginning of the text with the HOME key, then hold the SHIFT key down, and use the RIGHT ARROW key to highlight text. Use CTRL + C to copy the highlighted text, and then right arrow to clear the highlight. Then use CTRL + V to paste that text back at the current cursor position. If any of these steps do not operate as indicated, the test fails.
• CTRL + TAB should navigate through successive pages of multi-paged dialog boxes.
• Also, for multi-paged dialog boxes, use TAB to move to the page tab label, then RIGHT ARROW to move from one page (of the multi-page dialog) to the next.
• ESC key will typically close an open dialog box.

Document Results: If any component cannot be used with the keyboard alone, document the deficiency, and report it under “Comments” for element A on the Section 508 evaluation checklist, 1194.21(a).

Focus Test (Element C)

Note that this test must be conducted concurrently with the keyboard test, above.

With each keyboard navigation keystroke, observe if the focus changes (that is, look for a physical change on the screen indicating your new position. This can be a color change, highlight change, dotted line around a new element, etc.) Sometimes the focal point change is very subtle, and you may need to move one step back in the sequence and repeat the movement to the new focal point to observe the change in on-screen focus. If there is no visible evidence of a change in focus, the focus test fails for this particular component, and the outcome must be documented (see below, under “DOCUMENT RESULTS”). Whether or not you see a focus change may be inconsistent. For example, a dialog box may show focus changes for all but one or two elements. If there is any information that the user must be aware of that is not included in the cycling through focal points, then the focus test fails for that component.

Remember that the focus must be able to be moved to any area of on-screen information. The following situations represent typical problems of focus that indicate a failure in the focus test:

• Dual focus points. (For example, TABbing to a component in a dialog box presents an explanation of that component in another area of static text in that dialog box. Here there are two focus points, and there is no automatic way for assistive technology — screen reader or screen enlarger — to deal with this; consequently this is a failure of the focus test (element C) and it should be documented).
• Information areas on-screen that include instructions or other data important to the user that are not able to be “focused upon” with keyboard movement of the focus. (For example, explanatory text, hints.) Prompts are NOT a problem, as long as they are in proximity to the edit field or control they are connected with. The best way to test whether or not on-screen information is included in the focus, or programmatically exposed to assistive technology is to listen for the on-screen information during the entire cycle of keyboard navigation, with the screen reading program running. If the information area is not spoken by a screen reading program, it fails this test, and the missed information should be documented in remarks for element C.

Document Results: If there is no evident change in on-screen focus as you navigate through one or more components of an application, document the deficiency, and report it under “Comments” for element C on the Section 508 evaluation checklist, 1194.21(c).

Screen Reading Test (Element D)

Note that this test should be conducted concurrently with the keyboard test, above, or it may be conducted later, repeating the keyboard test as the primary technique used to evaluate screen reading. To run this test, the screen reading program (e.g., JAWS) should be loaded and active. [Note that the demonstration version of JAWS only runs for approximately 40 minutes, then closes. To restart JAWS, you will need to restart the computer and then reload JAWS.] With each keyboard movement that triggers a change in the focus, note whether the contents at the physical focal point is consistent with what the screen reading program is speaking. If it is not, this is a failure in the screen reading test (element D). If you want to “replay” what the screen reader spoke, use the keyboard to move one step backward in the sequence, then go forward again to return the focal point to the position where the screen reader spoke the focus, and listen again. Typical “reverse and then forward” keystrokes are SHIFT + TAB, followed by TAB, or UP ARROW, followed by DOWN ARROW. The following points should be checked carefully in the screen reading test:

• · Are all prompts for edit fields or radio buttons spoken?
• · Are all prompts or labels over other controls, such as list boxes, spoken?
• · Are other informational areas of text spoken, appropriately, as you navigate through the application, dialog box, or other component?
• · Are there areas of on-screen information that seem to be ignored by the screen reading program?

Document Results: If the screen reading program does not speak the contents of the new focal point each time you change focal point, or if it does not explain context by speaking prompts or text associated with that focus and which would be needed to understand what to do at that point, then document the deficiency, and report it under “Comments” for element D on the Section 508 evaluation checklist, 1194.21(d).

ELEMENT B (No Disruption of Accessibility Features): “Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.”

ACTION STEPS:

There are certain elements built into the operating system that represent accessibility features. These include accessibility aids (under Settings … Control Panel … Accessibility) such as “sticky keys” that allow a user to press one key at a time in a sequence instead of pressing two or more keys at once; and accommodating changes in user preferences, including, for example, enlarging system wide fonts. Two quick tests will serve to qualify whether the application meets the requirements of element B of the Section 508 Evaluation Checklist. Before running these two tests, unload the screen reading program (for example, with JAWS, use Insert + F4 to close the program, and respond with a SPACE BAR on the OK button to close the program).

“StickyKeys” Test:

The purpose of this test is to determine if having the StickyKeys accessibility aid running allows you to use StickyKeys to control your application. The test is not comprehensive, and only tests one keystroke combination, ALT + F4, which should close your application. If this test fails, however, it is reasonable evidence that the application may not be compatible with some accessibility aids.

• Be sure the application under test is running.
• Set up sticky keys: Select the START menu, select SETTINGS, select CONTROL PANEL, select “Accessibility Options,” press the SPACE BAR at the “Use StickyKeys” check box, and press ENTER. A dialog appears, asking if you want to save the settings for the default user. Press the “N” key for “No.” (Follow the same exact steps, later, when the test is complete, to disable StickyKeys)
• To switch to your running application, do NOT use ALT + TAB. Instead, use the MOUSE to click on your application on the task bar at the bottom of the screen.
• In your application, tap the ALT key, alone. You should hear a noise from the speakers. Then tap the F4 function key. Your application should close.

If you heard no noise from the speakers when pressing the ALT key, StickyKeys may not be properly loaded. Repeat the steps, above. Otherwise, if you heard the noise when pressing the ALT key, and if the application does not close, the test fails, and the outcome should be reported under “Comments” for element B on the Section 508 evaluation checklist, 1194.21(b).

Menu Font Size Test:

The purpose of this test is to determine whether user preference changes in overall system settings, such as the size of menu fonts, affect the application. Applications which circumvent operating system conventions for managing screen fonts, font sizes, etc., may fail this test.

• Be sure the application you are testing is running.
• Change menu font size, as follows: Select the START menu, select SETTINGS, select CONTROL PANEL, select “Display,” then press CTRL + TAB to move to the “Appearance” page of the Display dialog. TAB three times to move to the “Item” setting, then press “M” for “Menu.” TAB four more times to the font size, type 14 and press the ENTER key. The font size in your application’s menu bar should have increased, and reformatted to accommodate the larger menu font size. Repeat this step to return the menu font size back to its previous setting, usually 8 point.

If you heard no noise from the speakers when pressing the ALT key (it sounds like a “squeak”), StickyKeys may not be properly loaded. Repeat the steps, above. Otherwise, if you heard the noise when pressing the ALT key, and if the application does not close, the test fails.

Document Results: If one or both of these two tests fail, document the deficiency, and report it under “Comments” for element B on the Section 508 evaluation checklist, 1194.21(b).

ELEMENT E (Consistent meanings for bitmap images): “When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application’s performance.”

ACTION STEPS:

This element should be tested by visual observation of the application, looking for any inconsistency in the use of bitmap images and their associated meaning or purposes. For example, if a search button is represented in one component of the application as a bitmap image that looks like a magnifying glass, and if, in another component of the application, the search button appears to be a bitmap image of a finger pointing to a page in a book, these are not consistent, and the test fails.

Document Results: If there is inconsistent use of bitmap images, this should be documented in element E on the Section 508 evaluation checklist, 1194.21(e).

ELEMENT F (Text should be text, not an image): “Textual information shall be provided through operating system functions for displaying text. The minimum information that shall be made available is text content, text input caret location, and text attributes. “

ACTION STEPS:

Whether or not what APPEARS to be text on the application screen is ACTUALLY text can usually be determined by using a feature of the screen reading program, JAWS, called the JAWS cursor. If an area of the screen APPEARS that it may not be text, but rather might be a graphic image that incorporates text as a part of the graphic image itself, test for the existence of text as follows:

With JAWS running, tap the “-” key in the upper right corner of the numeric keypad. JAWS should report, “JAWS cursor.” Now, use the numeric keypad ARROW keys to move what appears as the mouse cursor to the area of the screen to be tested, and move the cursor in this way across the text itself. If JAWS reads the text, the text information is being provided through operating system functions for displaying text. If JAWS does not read the text or if it reports “graphic,” the test fails.

Document Results: If there is text embedded in a graphic in the application, and it cannot be read by the screen reading program, this should be documented in element F on the Section 508 evaluation checklist, 1194.21(f).

ELEMENT G (Respect user color/contrast settings): “Applications shall not override user selected contrast and color selections and other individual display attributes.”

ACTION STEPS:

In all versions of Windows, the user has the ability to change the contrast and color selections that apply to all Windows applications and to the desktop. Some Windows applications override this system-wide setting, and that application is not compliant with element G. [Note: system policy may not allow the user to change system colors. This policy is not permitted under element G of Section 508.] To test this, select the START menu, then SETTINGS, then CONTROL PANEL, then DISPLAY. Then use CTRL + TAB to move to the “Appearance” tabbed dialog page, and press “H” to select “High Contrast Black” and press ENTER.

Now, use ALT + TAB to return to your application and test menus, dialogs, edit fields, and all other interface components. If they appear to be white foreground letters and dark background, and all elements of the application have changed, consistent with the system-wide setting of color and contrast, then the application passes this element. If any part of the application still appears to have a white background, then the application fails.

To “undo” the color and contrast selection and return it to “Windows Standard,” select the START menu, then SETTINGS, then CONTROL PANEL, then DISPLAY. Then use CTRL + TAB to move to the “Appearance” tabbed dialog page, and press “W” twice to select “Windows Standard” and press ENTER. Then ALT + F4 to close the Control Panel.

Document Results: If, after the system-wide contrast/color change is made, the application has components that are white background, or if any other foreground or background color combination is UNAFFECTED by the system-wide color change, this should be documented in element G on the Section 508 evaluation checklist, 1194.21(g).

ELEMENT H (Provided non animated alternates to animation): “When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.”

Document Results: If there is animation in the application, and there is no non-animated option to display the same information, this should be documented in element H on the Section 508 evaluation checklist, 1194.21(h).

ELEMENT I (Color not sole way to convey information): “Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.”

ACTION STEPS:

Color coding, such as the instruction, “please complete the fields in ‘red'” is not allowable unless it is also accompanied by an alternate instruction, such as “please complete the fields in ‘red’ which are also indicated by the word ‘REQUIRED’ at the beginning of the question.” Check the application for references to colors in prompts or instructions and determine if an alternative means is provided to understand the same information for those who cannot distinguish the color referred to in the instruction.

Document Results: If color is the sole means used in a prompt or instruction, this should be documented in element I on the Section 508 evaluation checklist, 1194.21(i).

ELEMENT J (When color/contrast used, offer variety to the user): “When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.”

ACTION STEPS:

This item is similar to element G, but G applies to user control over system-wide contrast and color and whether the application conflicts with this. Element J addresses the feature of an application that can provide the user with contrast or color selections WITHIN THE APPLICATION. If the application supports this, be sure that the application FIRST meets element G’s requirements, and will allow the user to set system-wide settings and have it override the application’s individual color settings. It is not acceptable to merely provide color controls in the application that can mimic system-wide color settings; they must be capable of being overriden entirely by system-wide colors. After ensuring that system wide colors can override the application’s specific colors (and user options for colors), then test the user-definable color and contrast settings, and ascertain whether a sufficient variety is offered to provide contrasting foreground/background colors. If user-selectable color combinations do not provide low to high contrast levels (between foreground and background), then the application fails on this element.

Document Results: If user selectable colors do not provide a wide range of contrast levels, this should be documented in element J on the Section 508 evaluation checklist, 1194.21(j).

ELEMENT K (No quick flash or blinks): “Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.”

ACTION STEPS:

Observe whether there is flashing or blinking text in the application, and then observe whether it looks like it is blinking more than two times per second. If it flashes more than 55 times per second, the eye will generally regard it as NOT FLASHING. If visible flashing is evident, at more than two times per second, the application fails to conform to element K.

Document Results: If flashing or blinking text occurs in the application more than two times a second, or less than 55 times per second, this should be documented in element K on the Section 508 evaluation checklist, 1194.21(k).

ELEMENT L (Electronic Forms work with Assistive Technology): “When electronic forms are used, the form shall allow people using Assistive Technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.”

ACTION STEPS:

This test only applies to electronic forms or forms-like applications. This test is best conducted in conjunction with the screen reading program, and concurrent with the testing for elements A, C, and D.

As you use the keyboard (e.g., typically the TAB or CURSOR keys) to navigate through the form, ensure that the screen reading program reads ALL information that is available to a sighted user. Note especially:

— instructions

— directions about filling out a specific field that may be located above, below, or to the right of the field, and that are separate from the field prompt itself

— error messages

— color coding for mandatory fields

— any other explanations that provide cues or other information for the user.

The navigation technique that you use for navigating through the form should be the same technique that automatically provides spoken cues for each part of the form. While instructions may be present at the beginning of a group of questions, unless they are read during the typical navigation keystroke sequence, there will be no logical way to associate the instructions with the questions or fields to which they are related. If the standard means for navigation from one field to the next bypasses instructions, directions, and cues, then the electronic form fails to conform to the element L.

Document Results: If any prompt, direction, explanation, or instruction on a form is not spoken by the screen reading program, this should be documented in element L on the Section 508 evaluation checklist, 1194.21(l).

Section 4. Technical Approaches to Ensuring Accessibility of Web Pages

Thirteen Rules for Web Accessibility
Federal IT Accessibility Initiative
Implementing Section 508
of the Rehabilitation Act

1. Provide Alternate Text
A text equivalent for every non-text element shall be provided via “alt” (alternative text attribute), “longdesc” (long description tag), or in element content. This applies to:

• Images and graphical buttons
• Graphical representations of text (including symbols)
• Image map regions
• Animations
• Applets and programmatic objects
• ASCII art (two slides)
• Frames
• Scripts
• Images used as list bullets
• Images used as “spacers”
• Sounds (played with or without user interaction)
• Stand-alone audio files
• Audio tracks of video
• Described video

2. Meaning must be independent of color
Web pages shall be designed so that all information required for navigation or meaning is not dependent on the ability to identify specific colors.

3. Identify language changes
Changes in the natural language (e.g., English to French) of a document’s text and any text equivalents shall be clearly identified.

• For short passages of different languages within a page
• When the entire page is in different language

4. Style sheet independent
Documents shall be organized so they are readable without requiring an associated style sheet.

5. Update equivalents for dynamic content
Web pages shall update equivalents for dynamic content whenever the dynamic content changes.

• Image used FRAMES
• FRAMES and dynamic content created by SCRIPTS

6. Redundant text links for server-side image maps whenever possible
Redundant text links shall be provided for each active region of a server-side image map.

7. Use client-side image maps whenever possible
Client-side image maps shall be used whenever possible in place of server-side image maps.

8. Row and Column Headers in Data Tables
Data tables shall provide identification of row and column headers.

9. Data cells must be associated with header cells
Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

10. Title all frames
Frames shall be titled with text that facilitates frame identification and navigation.

• Simple titles
• Complex frameset descriptions

11. Script Independent
Pages will be usable when scripts, applets or other programmatic objects are turned off or are not supported or shall provide equivalent information on an alternative accessible page.

• When the user doesn’t support scripts or plug-ins, they must have an alternative.
• When the user does support scripts, they must be as accessible as possible.
• When the page serves a programmed application, the application must be accessible.

12. Synchronize multimedia equivalents
Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

• Synchronization
• A text transcript of audio material is required and when synchronized with the multimedia, is called “captioning”
• A text or audio description of action and scenery in a video is required, and when synchronized with the multimedia, is called “video description”

13. Provide option to skip repetitive links
An appropriate method shall be used to facilitate the easy tracking of page content that provides users of assistive technology the option to skip repetitive navigation links.

Related web sites:

• Federal IT Accessibility Initiative (http://www.section508.gov/)
• Center for IT Accommodation (CITA) (http://www.itpolicy.gsa.gov/ cita )

See also Guidelines from the Access Board, at

http://www.access-board.gov/ sec508/guide/1194.22.htm

Section 5. Technical Approaches to Ensuring Accessibility of Documents

The following guidelines should be used when creating documents that are posted on web pages for public use, or made available in electronic form to employees. Applying these guidelines will help to remove barriers to accessibility:

Using text descriptions. Microsoft Office documents that contain graphics, graphs, photographs or other images should include text descriptions of the graphic elements immediately before or after the graphic and in enough detail that the reader understands the content. In HTML and PDF documents, the graphics, graphs, photographs or other images should be properly tagged (e.g., using ALT text in HTML) to provide sufficient detail to allow individuals who are blind or low vision to understand the information that is included in the graphic.

Creating accessible documents. For USDA employees, documents may be in Microsoft Office file formats but must be made accessible taking into account the following requirements:

• · Microsoft Word documents should not have protected zones, and should
• · be fully editable, and cursor navigable throughout the document. To test this, use the keyboard alone to navigate throughout the document, and place the cursor in all areas of the document, including explanatory text preceding entry fields. (Examples of problem documents: those that have explanatory text and fill-in “fields” where the explanatory text is not navigable by the user’s cursor, and where keyboard navigation is limited to only fillable “fields”.)
• · Microsoft Word documents should not contain “text boxes” nor Word Art, both of which pose accessibility barriers to persons with low vision and mobility impairment.

Setting up tables for accessibility. Microsoft Office documents containing tabular data should be created using the table creation tools, and not using the TAB key to construct a simulated table. Headings should appear at the top of a table in the first table row, and should be fully descriptive of the data in the underlying column below the heading. The top row of a table should not include the table title spanning several columns of a table; rather, include the table title on a text line immediately preceding the table. For web pages with tables, properly tag table elements, including using table header (TH), ID and TITLE attributes to facilitate table navigation.

Creating accessible spreadsheets. Wherever text is used in a Microsoft Excel spreadsheet, the complete content of the text item must be included in a single cell, and NOT carried over from one row to the next, nor stacked vertically in multiple cells. Word wrap should be enabled to allow single cell text to be displayed properly without extending into adjoining cells. Multiple level headings should be avoided, including heading cells that span several columns.

Creating accessible presentations. Prepare Microsoft PowerPoint presentations so that graphics enhance the message but do not comprise the message itself. For example, each slide should present its content fully in text or at least should include text that explains and describes graphics. Then, to check accessibility, view the “outline” view of the presentation to ensure that the outline text presents the presentation fully. Then to save an accessible version of the Powerpoint presentation, save it as an “rtf” file, which includes the full outline content. This version of the presentation may be used by employees with visual disabilities to access the presentation, or it may be used as the basis for an HTML version of the presentation with or without accompanying (“alt-text tagged”) graphics. If PowerPoint’s built-in function for creating an HTML version of the presentation is used and posted on an internet or intranet web site, the site should include links to the HTML version as well as an alternative link to the text version (which is constructed using the rtf file incorporating the text outline).

Using tagging in PDF documents. Adobe Portable Document Format (PDF) documents should be created using Adobe Acrobat version 6 or later software, or equivalent tools from Adobe. All elements should be properly tagged, using the “make accessible” feature, in order to make the documents as compliant as possible with the Section 508 requirements.

Where possible, for internet documents, create a text-only or HTML equivalent of all PDF documents. Even when the “make accessible” feature is used, and elements are properly tagged, some screen reading software used in conjunction with Adobe Acrobat still cannot assure accessibility. Providing an HTML or text alternative provides the widest possible accessibility to members of the public.

For intranet documents, PDF documents should always be accompanied by an alternative document in Microsoft Office file format, or HTML format that is properly coded according to the Section 508 web accessibility standards (e.g., tables).

PDF documents that contain scanned images as the base for the entire document are not compatible with assistive technologies. Scanned PDF documents should be converted to text using the Adobe Paper Capture feature, or using the original electronic form of the document, where available. For internal employee use, the document should then be saved in Microsoft Office format, or in HTML format for posting on public web sites.

Adobe PDF forms can be made accessible by making them fillable using the Adobe Acrobat 6 or later software. This will enable an individual using Adobe Reader 6 or later to fill out the form on their computer and print a copy. To make the PDF forms accessible, the “make accessible” feature is applied to the form, the form tool is used to make the fields fillable, and alternate text is added to each field so that the assistive technologies can access the field labels.

ATTACHMENT SEVEN TO AGAR ADVISORY NO. 49

SAMPLE CHECKLIST OF STANDARDS (Version 05/16/2001)

During Market Research to define needs for electronic and information technology, the requirements official(s) should consider the following measurement indicators and statements from 36 CFR Part 1194, to the products or services needed:

N No compliance and there is no expectation of compliance.

E Eventually will be made compliant, but does not comply now.

S__% Somewhat compliant, and no expectation of full compliance.

P__% Partially compliant with progress toward full compliance.

F Fully compliant.

(1) Equivalent Facilitation:

People with disabilities are provided substantially equivalent or greater access to and use of items provided through use of designs or technologies other than those prescribed in 36 CFR Part 1194. Explain which features or components use equivalent facilitation and how it provides substantially equivalent or greater access:_______________________ ___________________

(2) Software applications and operating systems.

(i) When software is designed to run on a system that has a keyboard, product functions are executable from a keyboard where the function itself or the result of performing a function can be discerned textually.

(ii) Applications do not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications do not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.

(iii) A well-defined on-screen indication of the current focus is provided that moves among interactive interface elements as the input focus changes. The focus is programmatically exposed so that assistive technology can track focus and focus changes.

(iv) Sufficient information about a user interface element including the identity, operation and state of the element is available to assistive technology. When an image represents a program element, the information conveyed by the image is also available in text.

(v) When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images is consistent throughout an application’s performance.

(vi) Textual information is provided through operating system functions for displaying text. Text content, text input caret location, and text attributes are available.

(vii) Applications do not override user selected contrast and color selections and other individual display attributes.

(viii) When animation is displayed, the information is displayable in at least one non-animated presentation mode at the option of the user.

(ix) Color coding is not used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

(x) When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels are provided.

(xi) Software does not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.

(xii) When electronic forms are used, the form allows people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

(3) Web-based intranet and internet information and applications.

(i) A text equivalent for every non-text element is provided (e.g., via “alt”, “longdesc”, or in element content).

(ii) Equivalent alternatives for any multimedia presentation are synchronized with the presentation.

(iii) Web pages are designed so that all information conveyed with color is also available without color, for example from context or markup.

(iv) Documents are organized so they are readable without requiring an associated style sheet.

(v) Redundant text links are provided for each active region of a server-side image map.

(vi) Client-side image maps are provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.

(vii) Row and column headers are identified for data tables.

(viii) Markup is used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.

(ix) Frames are titled with text that facilitates frame identification and navigation.

(x) Pages are designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

(xi) A text-only page, with equivalent information or functionality, is provided to make a web site comply with the Access Board Standards (36 CFR Part 1194) when compliance cannot be accomplished in any other way. The content of the text-only page is updated whenever the primary page changes.

(xii) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script is identified with functional text that can be read by assistive technology.

(xiii) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page provides a link to a plug-in or applet that complies with 36 CFR 1194.21(a) through (l).

(xiv) When electronic forms are designed to be completed on-line, the form allows people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

(xv) A method is provided that permits users to skip repetitive navigation links.

(xvi) When a timed response is required, the user is alerted and given sufficient time to indicate more time is required.

(4) Telecommunications products.

(i) Telecommunications products or systems which provide a function allowing voice communication and which do not themselves provide a TTY functionality provide a standard non-acoustic connection point for TTYs. Microphones are capable of being turned on and off to allow the user to intermix speech with TTY use.

(ii) Telecommunications products which include voice communication functionality support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.

(iii) Voice mail, auto-attendant, and interactive voice response telecommunications systems are usable by TTY users with their TTYs.

(iv) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, give an alert when the time interval is about to run out, and provide sufficient time for the user to indicate more time is required.

(v) Where provided, caller identification and similar telecommunications functions are also available for users of TTYs, and for users who cannot see displays.

(vi) For transmitted voice signals, telecommunications products provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, at least one intermediate step of 12 dB of gain is provided.

(vii) If the telecommunications product allows a user to adjust the receive volume, a function is provided to automatically reset the volume to the default level after every use.

(viii) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies is provided.

(ix) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) is reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.

(x) Products that transmit or conduct information or communication, will pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format. Technologies which use encoding, signal compression, format transformation, or similar techniques do not remove information needed for access or restore it upon delivery.

(xi) Products which have mechanically operated controls or keys, comply with the following:

(A) Controls and keys are tactilely discernible without activating the controls or keys.

(B) Controls and keys are operable with one hand and do not require tight grasping, pinching, or twisting of the wrist. The force required to activate controls and keys is 5 lbs. (22.2 N) maximum.

(C) If key repeat is supported, the delay before repeat is adjustable to at least 2 seconds. Key repeat rate is adjustable to 2 seconds per character.

(D) The status of all locking or toggle controls or keys is visually discernible, and discernible either through touch or sound.

(5) Video and multimedia products.

(i) All analog television displays 13 inches and larger, and computer equipment that includes analog television receiver or display circuitry, are equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals. As soon as practicable, but not later than July 1, 2002, widescreen digital television (DTV) displays measuring at least 7.8 inches vertically, DTV sets with conventional displays measuring at least 13 inches vertically, and stand-alone DTV tuners, whether or not they are marketed with display screens, and computer equipment that includes DTV receiver or display circuitry, are be equipped with caption decoder circuitry which appropriately receives, decodes, and displays closed captions from broadcast, cable, videotape, and DVD signals.

(ii) Television tuners, including tuner cards for use in computers, are to be equipped with secondary audio program playback circuitry.

(iii) All training and informational video and multimedia productions which support the agency’s mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, are open or closed captioned.

(iv) All training and informational video and multimedia productions which support the agency’s mission, regardless of format, that contain visual information necessary for the comprehension of the content, are audio described.

(v) Display or presentation of alternate text presentation or audio descriptions are user-selectable unless permanent.

(6) Self contained, closed products.

(i) Self contained products shall be usable by people with disabilities without requiring an end-user to attach assistive technology to the product. Personal headsets for private listening are not assistive technology.

(ii) When a timed response is required, the user is alerted and given sufficient time to indicate more time is required.

(iii) Where a product utilizes touch screens or contact-sensitive controls, an input method is provided that complies with 36 CFR 1194.23 (k) (1) through (4).

(iv) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, is also provided.

(v) When products provide auditory output, the audio signal is provided at a standard signal level through an industry standard connector that will allow for private listening. The product provides the ability to interrupt, pause, and restart the audio at anytime.

(vi) When products deliver voice output in a public area, incremental volume control is provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level is user selectable. A function is provided to automatically reset the volume to the default level after every use.

(vii) Color coding is not used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.

(viii) When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels is provided.

(ix) Products are designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.

(x) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls comply with the following:

(A) The position of any operable control is determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length.

(B) Where any operable control is 10 inches or less behind the reference plane, the height is 54 inches maximum and 15 inches minimum above the floor.

(C) Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height is 46 inches maximum and 15 inches minimum above the floor.

(D) Operable controls are not more than 24 inches behind the reference plane.

(7) Desktop and portable computers.

(i) All mechanically operated controls and keys comply with 36 CFR 1194.23 (k) (1) through (4).

(ii) If a product utilizes touch screens or touch-operated controls, an input method is provided that complies with 36 CFR 1194.23 (k) (1) through (4).

(iii) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, is also provided.

(iv) Where provided, at least one of each type of expansion slots, ports and connectors complies with publicly available industry standards.

(8) Functional performance criteria.

(i) At least one mode of operation and information retrieval that does not require user vision is provided, or support for assistive technology used by people who are blind or visually impaired is provided.

(ii) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 is provided in audio and enlarged print output working together or independently, or support for assistive technology used by people who are visually impaired is provided.

(iii) At least one mode of operation and information retrieval that does not require user hearing is provided, or support for assistive technology used by people who are deaf or hard of hearing is provided.

(iv) Where audio information is important for the use of a product, at least one mode of operation and information retrieval is provided in an enhanced auditory fashion, or support for assistive hearing devices is provided.

(v) At least one mode of operation and information retrieval that does not require user speech is provided, or support for assistive technology used by people with disabilities is provided.

(vi) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength is provided.

(9) Information, documentation, and support.

(i) Product support documentation provided to end-users is available in alternate formats upon request, at no additional charge.

(ii) End-users have access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request, at no additional charge.

(iii) Support services for products accommodate the communication needs of end-users with disabilities.

APPENDIX I

Section 508 Evaluation Checklist

Section 1194.21 Software Applications and Operating Systems
Criteria	How Supported?	Comments
(a) When software is designed to run on a system that has a keyboard, product functions shall be executable from a keyboard where the function itself or the result of performing a function can be discerned textually.
(b) Applications shall not disrupt or disable activated features of other products that are identified as accessibility features, where those features are developed and documented according to industry standards. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.
(c) A well-defined on-screen indication of the current focus shall be provided that moves among interactive interface elements as the input focus changes. The focus shall be programmatically exposed so that Assistive Technology can track focus and focus changes.
(d) Sufficient information about a user interface element including the identity, operation and state of the element shall be available to Assistive Technology. When an image represents a program element, the information conveyed by the image must also be available in text.
(e) When bitmap images are used to identify controls, status indicators, or other programmatic elements, the meaning assigned to those images shall be consistent throughout an application’s performance.
(f) Textual information shall be provided through operating system functions for displaying text. The minimum information that shall be made available is text content, text input caret location, and text attributes.
(g) Applications shall not override user selected contrast and color selections and other individual display attributes.
(h) When animation is displayed, the information shall be displayable in at least one non-animated presentation mode at the option of the user.
(i) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.
(j) When a product permits a user to adjust color and contrast settings, a variety of color selections capable of producing a range of contrast levels shall be provided.
(k) Software shall not use flashing or blinking text, objects, or other elements having a flash or blink frequency greater than 2 Hz and lower than 55 Hz.
(l) When electronic forms are used, the form shall allow people using Assistive Technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.

Section 1194.22 Web-based Internet information and applications
Criteria	How Supported?	Comments
(a) A text equivalent for every non-text element shall be provided (e.g., via “alt”, “longdesc”, or in element content).
(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.
(c) Web pages shall be designed so that all information conveyed with color is also available without color, for example from context or markup.
(d) Documents shall be organized so they are readable without requiring an associated style sheet.
(e) Redundant text links shall be provided for each active region of a server-side image map.
(f) Client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape.
(g) Row and column headers shall be identified for data tables.
(h) Markup shall be used to associate data cells and header cells for data tables that have two or more logical levels of row or column headers.
(i) Frames shall be titled with text that facilitates frame identification and navigation
(j) Pages shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
(k) A text-only page, with equivalent information or functionality, shall be provided to make a web site comply with the provisions of this part, when compliance cannot be accomplished in any other way. The content of the text-only page shall be updated whenever the primary page changes.
(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by Assistive Technology.
(m) When a web page requires that an applet, plug-in or other application be present on the client system to interpret page content, the page must provide a link to a plug-in or applet that complies with Û1194.21(a) through (l).
(n) When electronic forms are designed to be completed on-line, the form shall allow people using Assistive Technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.
(o) A method shall be provided that permits users to skip repetitive navigation links.
(p) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.

Section 1194.23 Telecommunications Products
Criteria	How Supported?	Comments
(a) Telecommunications products or systems which provide a function allowing voice communication and which do not themselves provide a TTY functionality shall provide a standard non-acoustic connection point for TTYs. Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.
(b) Telecommunications products which include voice communication functionality shall support all commonly used cross-manufacturer non-proprietary standard TTY signal protocols.
(c) Voice mail, auto-attendant, and interactive voice response telecommunications systems shall be usable by TTY users with their TTYs.
(d) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required.
(e) Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs, and for users who cannot see displays.
(f) For transmitted voice signals, telecommunications products shall provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, at least one intermediate step of 12 dB of gain shall be provided.
(g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.
(h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided.
(i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.
(j) Products that transmit or conduct information or communication, shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format. Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.
(k)(1) Products which have mechanically operated controls or keys shall comply with the following: Controls and Keys shall be tactilely discernible without activating the controls or keys.
(k)(2) Products which have mechanically operated controls or keys shall comply with the following: Controls and Keys shall be operable with one hand and shall not require tight grasping, pinching, twisting of the wrist. The force required to activate controls and keys shall be 5 lbs. (22.2N) maximum.
(k)(3) Products which have mechanically operated controls or keys shall comply with the following: If key repeat is supported, the delay before repeat shall be adjustable to at least 2 seconds. Key repeat rate shall be adjustable to 2 seconds per character.
(k)(4) Products which have mechanically operated controls or keys shall comply with the following: The status of all locking or toggle controls or keys shall be visually discernible, and discernible either through touch or sound.

Section 1194.24 Video and Multi-media Products
Criteria	How Supported?	Comments
(b) Television tuners, including tuner cards for use in computers, shall be equipped with secondary audio program playback circuitry.
(c) All training and informational video and multimedia productions which support the agency’s mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned.
(d) All training and informational video and multimedia productions which support the agency’s mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall be audio described.
(e) Display or presentation of alternate text presentation or audio descriptions shall be user-selectable unless permanent.

Section 1194.25 Self-Contained, Closed Products
Criteria	How Supported?	Comments
(a) Self contained products shall be usable by people with disabilities without requiring an end-user to attach Assistive Technology to the product. Personal headsets for private listening are not Assistive Technology.
(b) When a timed response is required, the user shall be alerted and given sufficient time to indicate more time is required.
(c) Where a product utilizes touchscreens or contact-sensitive controls, an input method shall be provided that complies with Û1194.23 (k) (1) through (4).
(d) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.
(e) When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime.
(f) When products deliver voice output in a public area, incremental volume control shall be provided with output amplification up to a level of at least 65 dB. Where the ambient noise level of the environment is above 45 dB, a volume gain of at least 20 dB above the ambient level shall be user selectable. A function shall be provided to automatically reset the volume to the default level after every use.
(g) Color coding shall not be used as the only means of conveying information, indicating an action, prompting a response, or distinguishing a visual element.
(h) When a product permits a user to adjust color and contrast settings, a range of color selections capable of producing a variety of contrast levels shall be provided.
(i) Products shall be designed to avoid causing the screen to flicker with a frequency greater than 2 Hz and lower than 55 Hz.
(j) (1) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: The position of any operable control shall be determined with respect to a vertical plane, which is 48 inches in length, centered on the operable control, and at the maximum protrusion of the product within the 48 inch length on products which are freestanding, non-portable, and intended to be used in one location and which have operable controls.
(j)(2) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is 10 inches or less behind the reference plane, the height shall be 54 inches maximum and 15 inches minimum above the floor.
(j)(3) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Where any operable control is more than 10 inches and not more than 24 inches behind the reference plane, the height shall be 46 inches maximum and 15 inches minimum above the floor.
(j)(4) Products which are freestanding, non-portable, and intended to be used in one location and which have operable controls shall comply with the following: Operable controls shall not be more than 24 inches behind the reference plane.

Section 1194.26 Desktop and Portable Computers
Criteria	How Supported?	Comments
(a) All mechanically operated controls and keys shall comply with Û1194.23 (k) (1) through (4).
(b) If a product utilizes touchscreens or touch-operated controls, an input method shall be provided that complies with Û1194.23 (k) (1) through (4).
(c) When biometric forms of user identification or control are used, an alternative form of identification or activation, which does not require the user to possess particular biological characteristics, shall also be provided.
(d) Where provided, at least one of each type of expansion slots, ports and connectors shall comply with publicly available industry standards

Section 1194.31 Functional Performance Criteria
Criteria	How Supported?	Comments
(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for Assistive Technology used by people who are blind or visually impaired shall be provided.
(b) At least one mode of operation and information retrieval that does not require visual acuity greater than 20/70 shall be provided in audio and enlarged print output working together or independently, or support for Assistive Technology used by people who are visually impaired shall be provided.
(c) At least one mode of operation and information retrieval that does not require user hearing shall be provided, or support for Assistive Technology used by people who are deaf or hard of hearing shall be provided
(d) Where audio information is important for the use of a product, at least one mode of operation and information retrieval shall be provided in an enhanced auditory fashion, or support for assistive hearing devices shall be provided.
(e) At least one mode of operation and information retrieval that does not require user speech shall be provided, or support for Assistive Technology used by people with disabilities shall be provided.
(f) At least one mode of operation and information retrieval that does not require fine motor control or simultaneous actions and that is operable with limited reach and strength shall be provided.

Section 1194.41 Information, documentation, and support.
Criteria	How Supported?	Comments
(a) Product support documentation provided to end-users shall be made available in alternate formats upon request, at no additional charge.
(b) End-users shall have access to a description of the accessibility and compatibility features of products in alternate formats or alternate methods upon request, at no additional charge.
(c) Support services for products shall accommodate the communication needs of end-users with disabilities.