Forthcoming Updates on Federal Section 508 Rules

Section 508 web accessibility standards were written as an amendment to the Rehabilitation Act in 1998. In web development terms, this isn’t short of an eternity — and in all practical sense defines an era. The web programming methods and styles of 1998 were radically different to what you see in normal use today. The Section 508 rules have been under revision recently, and were available for public comment until June 21, 2010. Unfortunately, my time didn’t allow me to take a look at these prior to the expiration of the public comment period — but that doesn’t lessen the importance of examining the revisions.

To help explain these changes in Federal web accessibility standards, I’m going to look at three specific questions. These questions will hopefully answer some of the questions concerning what’s coming up:

  1. Has this changed anything about who must follow Section 508 guidelines?
  2. What has been the primary reference for changes to Section 508 rules?
  3. What are the specific changes to the Section 508 documents?

Has this changed anything about who must follow Section 508 guidelines?

No. The section 508 rules still exist under the same body of law — this is not a revision of the application of the law, it’s only a revision of the methods which are acceptable in following the law. Section 508 continues to apply only to Federal departments or agencies or entities providing services or products to Federal agencies. Further, it only applies to the specific services or products provided by those contracted entities, not to any external presence or non-Federally funded projects.

What has been the primary reference for changes to Section 508 rules?

Based on the document guidelines and on references made in the updated document, it seems that the primary reference was the Web Content Accessibility Guidelines, Version 2.0, as created by the World Wide Web Consortium. In fact, there is a specific section referring to WCAG harmonization, which indicates that web pages as defined under WCAG 2.0 which are conformant to Level AA will be considered to be in conformance with Section 508 (with a few elaborations on additional requirements.)

This is an excellent change, since it explicitly states a subset of requirements which need to be reviewed in addition to WCAG 2.0, Level AA requirements. From a consulting perspective, this simplifies the process: you can review WCAG 2.0 requirements, then check the additional requirements under Section 508.

The additional requirements are fairly straightforward. A significant percentage of them relate explicitly to video accessibility — an area which WCAG 2.0 frequently describes as Level AAA requirements. It seems clear that the Section 508 review group was concerned about the use of video in government communications, and wanted to be sure to avoid a situation where creating a video would allow Federal agencies to ignore Section 508 requirements — which is certainly a wise concern.

What are the specific changes to the Section 508 documents?

To work through all of the specific changes would be a Herculean labor — and I’m not prepared to undertake it right this moment. I’m not sure an article is the right place to do this, in fact. A permanent document demonstrating the changes may be more valuable, in the long run. Suffice it to say that the basic fundamentals of Section 508 have been updated to reflect the changes between versions 1.0 and 2.0 of the Web Content Accessibility Guidelines. The requirements which are beyond the specific conformance expectations of WCAG 2.0, Level AA are worth elaborating on, however!

Chapter 4, section 409: User Preferences. This section explicitly requires that applications allow users to set preferences for color, contrast, font type, size, and focus cursor. Thankfully, the rule is clearly written when it comes to development which is operated within a web browser: web browsers, as platforms which take some settings from an underlying platform, are expected to allow the underlying platform’s settings for these issues to take precedence.

To clarify this in simple terms: web browsers, or applications running within web browsers should not over-ride settings from the operating system.

Chapter 4, section 413: Authoring Tools. Essentially, this is an extension of the web authoring tool accessibility guidelines applied within Section 508. What it requires is that any tool which is used to author content or create documents — such as Microsoft Word, as a desktop application, or as WordPress, as a web-based content authoring tool — must allow the creation of accessible documents (such as by allowing the creation of alt attributes for images) and must not by default remove any accessibility feature — such as a video editing tool which would remove captions if editing a captioned video.

The section seems very reasonably written — it requires prompts for creating conforming documents, but also specifies that not every element should be prompted, as this can decrease usability.

Chapter 6, section 604, part 4: Real-Time Video. Live, streaming video must include real-time video description, with certain exceptions. This seems pretty explicit, and definitely is a valuable addition for people with disabilities. The exception provides for an exclusion for primarily visual and unattended situations. The example provided is a web camera overlooking a national park — it is purely visual, and there is little to no significant information to be gained from live video description.

Chapter 6, section 604, part 5: Multiple Visual Areas of Focus. When a video contains multiple areas of focus — such as a news program which also includes scrolling event notices beneath the main program — video description must be provided for all areas of focus. The provision suggests a couple of methods for accomplishing this, including divided audio tracks between left and right channels. It’s an interesting area to address. I can certainly see that this requirement can open up new areas of information availability to people with disabilities, but I can also see a number of potential problems in implementation. However, that is a question for another time!

Chapter 6, section 607: User Controls for Captions and Video Description. User controls must meet certain standards for accessibility functionality: in addition to the requirement that controls for closed captions or video description need to be present, they must also be present in the same context as other controls. It is not an acceptable option to hide controls for closed captions or video description in a corner — they should appear in contexts which have a similar prominence to other controls such as channel selection or volume adjustment.

Chapter 6, section 608: Audio Track and Volume Control. Essentially, media players must provide users an ability to isolate speech tracks and background sounds. This is obviously dependent on video production in order to function; as such, this section indicates that any videos produced must be produced with separate speech and background audio tracks, in addition to requiring that players must offer controls to separately adjust these tracks.

This clause seems to have some flaws to me — specifically, in the gross generality of “background audio” versus “speech.” Stating “speech” is very explicit, as it only refers to spoken text. However, in practical terms, there are actually three important bands of audio in synchonized media: background audio which is non-referential (music and some background sound effects), audio which is referential (some background sound effects: a knock at the door or other sound which is reacted to by the video), and speech. It can create a great deal of confusion to exclude those key sound effects from the speech track. The issue is closely related to issues with captioning and video description: it’s important to note certain sound events, since some conversations or events will lose meaning if the viewer is unaware of relevant background sounds.

On the whole, in my relatively brief examination of the updates to Section 508 standards, I’m happy with the results. Obviously, there’s always room for improvement — there’s still room for improvement in WCAG 2.0, which Section 508 could have changed — but I’d rather have a single set of base standards to reference than requirements which contradict each other! Working with standards isn’t the answer to every accessibility quandary, but you should never just ignore standards out of ignorance — instead, ignore them out of an educated disagreement. ;)

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7 Comments to “Forthcoming Updates on Federal Section 508 Rules”

  1. Well Tom, I can’t honestly say I’m surprised. The government and glaciers are a good comparison with each other: very slow moving, and not always moving forward…

  2. Who would have thought in 2010 that it will take so much longer to take into effect.

  3. Thank you very much for the clarification, I was talking to another developer awhile back and he had me near convinced that this was going to be like how every restaurant has to have stalls of a certain size etc, that all sites would have to meet these standards. Still a bit confusing in some parts but I have a much clearer picture that this will not really affect my work.

  4. Testing Documents for Section 508 Compliance. search marketing

    * Each time you receive an electronic document, ensure that it is accessible.
    * Use of acquisition language ensures that at least one version will be accessible
    * Send a non-compliant document back to its creator for remediation!
    o Especially when working with non-departmental staff and consultants.
    * Documents that are submitted as part of the proposal cycle and as project deliverables (monthly reports, change requests) must meet Section 508.

  5. Thank you very much for the clarification, I was talking to another developer awhile back and he had me near convinced that this was going to be like how every restaurant has to have stalls of a certain size etc, that all sites would have to meet these standards. Still a bit confusing in some parts but I have a much clearer picture that this will not really affect my work.

  6. Thanks, Jay – although I don’t think there’s anything particularly ridiculous in the clauses. Given that Section 508 is a legal document, it needs to be couched in a format which leaves minimal room for interpretation — the legalese is a necessary part of the document.

  7. The clauses used to explain some of these guidelines are just ridiculous. Good job on trying to clarify them. Still looking for someone to do justice to the new FTC rules though.

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