RE: Section 508 Auditing - Level A vs Level AA

The Revised 508 Standards citations to WCAG are of the form:
…shall conform to Level A and Level AA Success Criteria and Conformance Requirements in WCAG 2.0 (incorporated by reference, see 702.10.1).

I find five matches for that exact phrase from our page here:
http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines


For folks familiar with the WCAG conformance requirements, that’s the same as “WCAG 2.0 Level AA”.

For folks unfamiliar with WCAG, I will use the longer phrasing.



From: Starry Sky <Starry_sky@live.com>
Sent: Wednesday, October 17, 2018 1:39 PM
To: Bruce Bailey <Bailey@Access-Board.gov>; w3c-wai-ig@w3.org
Subject: Section 508 Auditing - Level A vs Level AA


Hi Bruce - according to an exchange with a senior accessibility specialist at the Access Board, some 508 standards are only set at Level A and even then, only for "many" but not "all" 508 provisions:

"The WCAG 2.0 Level A and Level AA Success Criteria are applied to many of the provisions in the Revised 508 (2018) Standards. "

But per your reply, 2.0 Level AA is applied across all 508 standards.  Or, did I read that wrong?

Can you please clarify if there are any 508 standards only set to Level A or not to WCAG 2.0 at all?

Skye

-------- Original Message --------
From: Bruce Bailey<mailto:Bailey@Access-Board.gov>
Date: Wednesday, October 17, 2018 12:42 PM EDT
Subject: RE: AW: Section 508 Auditing
To: Peter Shikli<mailto:pshikli@bizware.com>, W3c-wai-ig<mailto:w3c-wai-ig@w3.org>
Cc: 508<mailto:508@Access-Board.gov>
My apologies Peter, you are correct that OAST is part of both the DHS OCR and DHS OCIO.  I also apologize for thinking that you meant the DOJ OCR and not the DHS OCR.

OAST is running Trusted Tester (1) because they have the resources (and the U.S. Access Board does not); and (2) because of how DHS came together, they needed something like Trusted Tester to bridge the differences between all the agencies that came together to form DHS.  Bill Peterson who created OAST came from ED (where I first met him) and he provided the vision and leadership needed to open Trusted Tester up to a larger audience.  As I understand it, the incremental cost of opening Trusted Tester was fairly marginal as compared to what needed to be done to address the 508 accessibility needs at DHS in any case.

My agency, the U.S. Access Board, writes accessibility regulations (and not just for 508) and we would have needed additional statutory authority (and funding) for something like Trusted Tester.  DHS developed Trusted Tester because it met their internal agency business needs.  Part of our statutory authority includes providing technical assistance (TA) with the standards we develop and promulgate.  We provide that TA to all sources, not just federal employees.  This is “why the feds have two organizations that seem to address Section 508 compliance”.

Please be assured that we (staff at the Access Board) consulted staff at OAST (and other Federal agencies) as we developed the Revised 508 Standards, since their real-world experience with the Original 508 Standards is so extensive.  It is also the case that OAST is coordinating with us now to ensure that Trusted Tester (as it is being updated) is aligned with the Revised 508 Standards (which, of course, cite WCAG 2.0 Level AA).  They have a recent press release about their progress:
http://www.dhs.gov/news/2018/10/01/accessibility-training-news<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.dhs.gov%2Fnews%2F2018%2F10%2F01%2Faccessibility-training-news&data=02%7C01%7CBailey%40access-board.gov%7Cf47d9c7f9c3840cf25ce08d6345770a2%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753947496440398&sdata=1lDxvlUFuGsp2fMV2l4q2uUPiklnVlAPuGd2BjUXECw%3D&reserved=0>

For an overview more information about the Access Board, and the training we can provide, please see:
http://www.access-board.gov/the-board<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.access-board.gov%2Fthe-board&data=02%7C01%7CBailey%40access-board.gov%7Cf47d9c7f9c3840cf25ce08d6345770a2%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753947496450410&sdata=p9IRSyIUpbAsADP3zYCvNBn1nYvHit43fLnnVV%2F9Kqc%3D&reserved=0>
http://www.access-board.gov/training<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.access-board.gov%2Ftraining&data=02%7C01%7CBailey%40access-board.gov%7Cf47d9c7f9c3840cf25ce08d6345770a2%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753947496450410&sdata=HOEu%2F9IFeCmYfZJFkHGtPc5%2ByYYxVZajFsDp%2BqYZlIo%3D&reserved=0>

--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC  20004-1111
202-272-0024 (voice)
202-272-0070 (TTY)
202-272-0081 (Fax)
bailey@access-board.gov<mailto:bailey@access-board.gov>

Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998.  Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section.  Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency.  Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.