Re: Question about: functional performance Statement (FPS) in European EN 301 549

First I'll acknowledge that EN 301 549 is a bit off-topic for the WAI list.
Nevertheless I'll go ahead and reply here, because (correct me if I'm
wrong) I haven't found any better forum for discussing practical
applications of EN 301 549.

It's true that the EN 301 549 Functional Performance Statements (FPS) are
not needed for reporting technical conformance to EN 301 549. However, ICT
buyers are encouraged to read the FPS. Here's a 2014 quote from ETSI
Technical Report 101 550[link 1 below].

Start of quote...
... How well ICT satisfies the user accessibility needs within the FPCs is
one of the most important things to understand about the ICT. The
expectation is that anyone wanting to know how accessible an ICT product is
would firstly ask how well the functional performance statements have been
met. Finding the answer to this question will enable a procuring body, or
anyone using the EN, to get a comprehensive understanding of how accessible
the ICT is. The more detailed picture of which of the requirements in the
EN have been met is significant evidence to demonstrate how the functional
performance statements have been satisfied.
...End of quote

This presumes that buyers are expecting accessible ICT from suppliers at
all. I'm afraid this is still far from universal. Are there any buyers
here, looking at EN 301 549 accessibility statements from suppliers (e.g.,
for public procurement in Europe or Australia)? What do you want to see in
a winning tender?

In the United States, VPAT[link 2 below] is the expected format for
reporting ICT accessibility for public procurement. VPAT also supports EN
301 549, with a section for FPS, but I don't know how often buyers are
actually reviewing VPAT-format EN 301 549 reports in tenders today.

For the Web Accessibility Directive (WAD), European public sector bodies
are using the Model Accessibility Statement[link 3 below]. These statements
do not directly list the individual EN 301 549 conformance clauses nor the
FPS, but agencies are encouraged to link to a full report in any format.
The audience is the general public, so it might make sense to include the
user-centered FPS in a full report.

So, if you choose to report FPS, how should you write the ratings and
remarks? The best answer I've seen is the full section "5.4 Functional
performance (Clause 4 of the EN)" in ETSI Technical Report 101 550[link 1
below], which is too long to quote here.

Again, my apologies for this long off-topic message. If you know a better
forum for this topic, I'd be happy to move the conversation there.

Link [1]: ETSI Technical Report 101 550
https://www.etsi.org/deliver/etsi_tr/101500_101599/101550/01.01.01_60/tr_101550v010101p.pdf

Link [2]: VPAT
https://www.itic.org/policy/accessibility/vpat

Link [3]: Model Accessibility Statement
https://eur-lex.europa.eu/eli/dec_impl/2018/1523/oj

Mitchell Evan
mtchllvn@gmail.com
+1 (510) 375-6104 mobile


On Wed, Sep 11, 2019 at 6:41 PM Sailesh Panchang <sailesh.panchang@deque.com>
wrote:

> Thanks all for your feedback.
> I am specifically looking for confirmation for the need to test for
> FPS when testing against the EN-standards, be it for ICT covered by
> the EU's WAD or any other iCT.
> I did refer to normative C.4 statement in my initial email that made
> me think one is not required to test for FPS. Shadi confirms this, so
> thank you!
> And I did look at the draft in the works. (Thanks James for the link)
> It has the identical C.4 text. The draft also confirms that only
> Clauses 5 to 13 contain testable requirements.
> Best wishes,
> Sailesh
>
>
> On 9/11/19, James A. <A.James@soton.ac.uk> wrote:
> > If you are looking at this standard in relation to the E.U.-wide public
> > sector web accessibility regulations then you may want to have a look at
> V3
> > of the standard (currently in draft waiting approval) may help -
> >
> https://www.etsi.org/deliver/etsi_en/301500_301599/301549/03.01.01_20/en_301549v030101a.pdf
> .
> > This adds Annex A describing how the standard can be used in relation to
> > compliance for the standard.
> >
> > Regards
> >
> > Abi James
> >
> > On 11 Sep 2019, at 21:31, Sailesh Panchang
> > <sailesh.panchang@deque.com<mailto:sailesh.panchang@deque.com>> wrote:
> >
> > Hello Listers,
> > My question relates to the functional performance statement in Clause
> > 4 on page 17 of   EN 301 549 standard.
> >
> > (The standard is available as a PDF at
> >
> https://eur03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.etsi.org%2Fdeliver%2Fetsi_en%2F301500_301599%2F301549%2F02.01.02_60%2Fen_301549v020102p.pdf&amp;data=01%7C01%7Ca.james%40soton.ac.uk%7Cb349faea0fe245c5f32b08d736f71411%7C4a5378f929f44d3ebe89669d03ada9d8%7C0&amp;sdata=dKvS7uBk4tIg8oum53Ef7u2Y8nKRQJx5qeSxIFh0rSo%3D&amp;reserved=0
> ?
> > (with serious tagging lapses)
> > Item C.4 of Annex C (normative) starting on page 96 states:
> > "Clause 4 is informative and does not contain requirements that
> > require testing".
> >
> > So am I interpreting this correctly  if I say, FPS of the EN-standard
> > never have to be explicitly tested separately?
> > One needs to only check against the applicable clauses 5 to 13 that
> > apply to an ICT.
> > Note:  the mapping for requirements in Clause 5 to 13 against the FPS
> > is given separately in Annex B of the standard.
> > Thanks in advance,
> >
> >
> > --
> > Sailesh Panchang
> > Principal Accessibility Consultant
> > Deque Systems Inc
> > 381 Elden Street, Suite 2000, Herndon, VA 20170
> > Mobile: 571-344-1765
> >
> >
>
>
> --
> Sailesh Panchang
> Principal Accessibility Consultant
> Deque Systems Inc
> 381 Elden Street, Suite 2000, Herndon, VA 20170
> Mobile: 571-344-1765
>
>