RE: minutes from 02/23 /2015 coga & 508

I definitely support the idea to request a functional performance criterion regarding cognitive language and learning disabilities.

When we created EN 301 549 "Accessibility requirements suitable for public procurement of ICT products and services in Europe" we were unable to identify unique requirements for cognitive language and learning disabilities that were both testable and widely accepted as appropriate. We did provide a table identifying which WCAG success criteria might also be beneficial to users in this group. We also included a "functional performance statement" on "Usage with limited cognition" - why ours is a "statement and not a criterion" is a very long story (which will no doubt re-surface during the 508 commenting)!

The titling for a Section 508 success criterion of "With limited cognition" would be more compatible with the other functional performance statement titles (the word "disabilities" is completely absent from Chapter 3). To ensure a broader scope we included a note "This clause is intended to include the needs of persons with limited cognitive, language and learning abilities".

Unfortunately the text of what Neil proposes for the core requirement differs significantly from the other functional performance criteria. These are heavily based on the approach we took in EN 301 549. They refer to an alternative mode of operation that does not rely on a specific ABILITY. Writing something related to cognitive, language and learning disabilities is extremely difficult!

A suggestion that maybe captures at least a fraction of what is needed is:

"302.9 With limited cognition
ICT shall provide at least one mode of operation that minimizes the need for the user to process information and decide between options.
NOTE:   This requirement is intended to address the needs of persons with limited cognitive, language and learning abilities."

Best regards,

Mike Pluke
Castle Consulting Ltd.
76 Cowper Street

From: Neil Milliken []
Sent: 26 February 2015 10:05
To: lisa.seeman; public-cognitive-a11y-tf
Subject: RE: minutes from 02/23 /2015 coga & 508

I was running late for taskforce meeting and then could not get on to Zakim so am making my comments here so that they are on the record.

I absolutely support Lisa's point of view that clear reference to Cognitive Disabilities must be included in the 508 refresh.  To wait for the next refresh in another 17 years time will mean that we have abandoned another generation.

Cognitive disabilities as you are all aware are some of the most common disabilities but equally most under represented when it comes to accessibility and inclusion.  We may not have commented previously but we are now. Since the refresh is open for comments now is the time to do so.

I think that Katie Haritos-Shea's suggestion of including Coga in the  Functional Performance Criteria is absolutely necessary as a minimum.

"Add: 302.9 With Cognitive Language and
   Learning Disabilities. Where a mode of operation is provided,
   ICT shall provide at least one mode of operation that is
   operable by persons with Cognitive Language and Learning

If the COGA taskforce have techniques ready in time then we should reference them, this is especially important since as I understand it the Access Board will only pointing to WCAG for techniques to meet A & AA.

Why as a Brit do I care about US legislation?

It's all about harmonisation and precedence setting;

As EU and US legislation looks to cross reference, standardise and harmonise we run the risk of creating an ecosystem of compliancy with standards and therefore with the laws that effectively excludes some of the largest groups of people with disabilities.

Kind regards,

Neil Milliken
From: lisa.seeman []
Sent: 26 February 2015 08:57
To: public-cognitive-a11y-tf
Subject: minutes from 02/23 /2015

The bot was being rest so our minutes from this weeks call are a bit late being published

and,text for the text only version
All the best

Lisa Seeman

Athena ICT Accessibility Projects <>
LinkedIn<>, Twitter<>

Received on Thursday, 26 February 2015 12:00:46 UTC