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

Mitchell,

Not to worry. EN 301 549 is not at all off-topic for the WAI IG list...:-)


On Fri, Sep 13, 2019, 6:36 PM Mitchell Evan <mtchllvn@gmail.com> wrote:

> 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
>>
>>