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


For an overview more information about the Access Board, and the training we can provide, please see:
http://www.access-board.gov/the-board

http://www.access-board.gov/training


--
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.


From: Peter Shikli <pshikli@bizware.com><mailto:pshikli@bizware.com>
Sent: Wednesday, October 17, 2018 10:27 AM
To: Bruce Bailey <Bailey@Access-Board.gov><mailto:Bailey@Access-Board.gov>; w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>; 508 <508@Access-Board.gov><mailto:508@Access-Board.gov>
Subject: Re: AW: Section 508 Auditing

Bruce,

Even after going through OAST's Trusted Tester Program myself, I'm still unsure why we have an OAST running that instead of the US Access Board.  Could you explain why the feds have two organizations that seem to address Section 508 compliance?

Also, the reason I said OAST is under both OCR and the federal CIO is because of the second sentence, "OAST is part of both the Office for Civil Rights and Civil Liberties and the Office of Chief Information Officer" at https://www.dhs.gov/office-accessible-systems-technology<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.dhs.gov%2Foffice-accessible-systems-technology&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502440326&sdata=AZZxmmrn5kwqCRtbCYYotsktJun60UsxjNs8CbddirQ%3D&reserved=0>.  Am I misreading that?

Cheers,
Peter

Bruce Bailey wrote on 10/17/2018 6:18 AM:
Peter (et al.),

There is no “federal office of civil rights” but OCR exist in a few different agencies, like HHS and ED.  But I am pretty sure you were referring to the one at DOJ:
http://www.justice.gov/crt<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.justice.gov%2Fcrt&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502450330&sdata=A69Y%2BJda3Ry2m1XUNOceVZnVaO7CKUGg%2FYdTrl%2FdJHI%3D&reserved=0>

DOJ does not enforce Section 508.  Federal agencies enforce 508 on themselves, as they do with other statutory requirements.

Your previous post<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Flists.w3.org%2FArchives%2FPublic%2Fw3c-wai-ig%2F2018OctDec%2F0014.html&data=02%7C01%7Cbailey%40access-board.gov%7C87e7bdc5dadd48752f8908d6343caa00%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C636753832502450330&sdata=P5oWSKIoJeKHB09ifxZIFohpwVGeXc%2FRBc52FH59qHQ%3D&reserved=0> correctly provides the best links to OAST, but please note that they are not “under the OCR” or the “federal CIO” but are part of the DHS Office of the (DHS) CIO.  It is a pretty straightforward relationship IMHO.

Your previous post also asserted that “The Section 508 folks say they "pivoted" to WCAG 2.1 AA”.  I am not aware of any “508 folks” saying anything like.  We here at the Access Board have been trying to disabuse people of that idea.  The Section 508 citation is to WCAG 2.0 Level AA, and we have no plans to update that citation.

--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC  20004-1111
508@access-board.gov<mailto:508@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.