usability trumps accessibility

8/14/2019 Usability Trumps Accessibility

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Usability TrumpsAccessibility

While Compliance is the most expensive,

least effective solution: Separate &

Unequal systems


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Outline

Legal & Administrative Provisions

Procurement Requirements & Tools

Why is this a big deal?

Why this is a big deal

Content is King Usability is Queen

Not an IT/IS Problem; Stakeholders Marginal Cost is Negligible if

Usability Bonus Dwarfs all costs

Validation & Remediation


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Legal Requirements

TheFlorida Accessible Electronic &

Information Technology Act of 2006

became law on July 1, 2006Chapter 282, Part III, Sections 282.601-282.606,F.S.

Section 60EE-1.1-004, F.A.C.,Florida

Accessible Electronic & Information

Technology Rules, Implementing the FA-eIT

Chapter 282, Part III, Sections 282.601-282.606,F.S.


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Scope of Requirements

Major Categories of Disabilities Visual

blindness, low vision, color-blindness

Hearing deafness

Motor inability to use a mouse, slow response time, limited fine

motor control Cognitive

learning disabilities, distractibility, inability to rememberor focus on large amounts of information


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Legal Requirements

The Americans with Disabilities Act(1990 - see 28 C.F.R. Part 35)

Section 504 of the Rehabilitation Act

Section 508 of the Rehabilitation Act

Assistive Technology Act of 1998

Telecommunications Act of 1996 Section 251 as amended 2000

Section 255 as amended 2002

Florida Accessible Electronic & InformationTechnology Act of 2006


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Dept of Justice ruling (9/9/96): ADA

accessibility requirements apply to Internet web pages(10NDLR 240)

Central issues focus on:

Effective Communication and

Public Accommodation.Covered entities under the ADA are required to provide effective communication,

regardless of whether they generally communicate through telecommunication devices, printmedia, audio media, or computerized media such as the Internet. Covered entities that use theInternet for communications regarding their programs, goods, or services must be preparedto offer those communications through accessible means as well.- Department of Justice

Legal Requirements: ADA


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Section 508 of the Rehabilitation Act This section requires the Federal government to procure electronic

and information technology (E&IT) goods and services that are not

fully accessible to those with disabilities.

Provides the legislative language and standards for the design of

accessible electronic information technology. (effective: June 21,

2001)

Section 508 is important because: It provides the first federal accessibility standard for the Internet.

It provides compliance language that can be automated and monitored at

a distance.

State governments can be held accountable under the Assistive

Technology Act of 1998.

Businesses must comply with Section 508 when supplying Electronic

and Information Technology goods and services to the federal

government.

Legal Requirements: 508


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Section 508 Accessible Electronic &

Information Technology Standards

Subpart B - Technical Standards

Software, web apps, computers, etc.

Subpart C - Functional Performance Criteria By type of impairment, e.g. vision and hearing

Subpart D - Information, Documentation, &Support Includes product support and product support services

in alternative formats and modes

Legal Reqs: 508 Subparts


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Florida Accessible Electronic &

Information Technology Act of 2006 Became law July 1, 2006

Creates part III of Section 282, F.S. (HB 1503, SB 2012)

Applies to the executive, legislative and judicial branches of state

government

Tracks Section 508 federal language

Allows the state to use the body of federal law and related

interpretations in regard to the administration of this Act. Requires agencies to use Section 508 1194 standards forprocuring,

developing, and maintaining A-eIT

Applies to competitive solicitations issuedand new systems

developed after July 1, 2006

Legal Requirements: FA-eIT


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Procurement Guidance

BuyAccessible.gov http://www.buyaccessible.gov/

See the Buy Accessible Wizard for your procurementactivities - http://app.buyaccessible.gov/baw/

Sample U.S. Agency Usability Contracts -http://www.usability.gov/sows/index.html

Federal Communications Commission:

Disability Rights Office(resource for Telecommunication/VoIP accessibility)http://www.fcc.gov/cgb/dro
http://www.buyaccessible.gov/http://app.buyaccessible.gov/baw/http://www.usability.gov/sows/index.htmlhttp://www.fcc.gov/cgb/drohttp://www.fcc.gov/cgb/drohttp://www.usability.gov/sows/index.htmlhttp://app.buyaccessible.gov/baw/http://www.buyaccessible.gov/


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Procurement Tool: VPAT

Product Category 1194.21 1194.22 1194.23 1194.24 1194.25 1194.26

A/V Equipment as identified in the Standards O

Copiers (not multi-function document imaging - see

Note 1) O

Digital Copiers O=PC Soft

O=Web

Interface O

Scanners O=PC Soft

Smart Card Readers O=PC Soft

Operating Systems, Application Software O

Websites O

Printers O=PC Soft O

Handhelds O=PC Soft O

Personal Computers (Desktop, Notebook, Portable,

including displays) O O=Tuner O

Servers and Workstations O O

Fax machines (public line or via the Internet) O=PC Soft O O

PBX (in-house electronic exchanger) O=TAPI O

Telephone answering machines O

Telecommunications devices (wired, analog and

digital wireless, Internet) O=PC Soft

O=Web

Interface O

Information Technology Industry Council

Volunteer Product Accessibility Template (VPAT)

O = Applies - PC Soft is the application software bundle - "TAPI" is the Telephony Application Programming Interface -

"Web Interface" refers to browser applications - "Tuner" refers to a television tuner/receiver. Note 1: If a product provides the equivalent

functionality of a combination of the products listed above, all relevant standards apply. Source: ITIC


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Legal Practical Actual

Compliance does not equal Accessibility Necessary but not Sufficient

Auditors game

Accessibility does not equal Usability Necessary but not Sufficient

Stakeholders game

Usability does not equal Political Needs Massive positive ROI (public interest serving) Requires patience, determination, deliberateness,

& sustained commitment

Not optimistic: completely out of character


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Why Is This a Big Deal?

Whos Job is it Anyway? Its the Organization, Not the Technology Where is the priority?

Where is the money?

Where is the focus?

What are the instructions?

It is wildly expensive to remediate It is negligibly costly to anticipate


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Why This is a Big Deal

Workers are more efficient Managers are more effective Customers are more satisfied

The Price:Proper Project Planning & Management

Realism derived from

Stakeholder Involvement Professional management

Resources adequate to the task(s)

We are temporarily able bodied


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All you able bodied people here

just need to realize:

You are only temporarily

able bodied.


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Usability Stakeholders

Workers & Customers Persons with disabilities are a subset of both

stakeholders

Persons with Disabilities requirements aresatisfied with Usability

Where Usability: Logical structure,

succinctly delineated,

concisely navigated,

crisply executed


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Workers Rights

Workers with Disabilities are Special Principle not yet understood of a Property

Interest in our jobs, a constitutional right

Poor usability renders the fundamentallycompetent and earnest, hard working,

ambitious (often the most knowledgeable &

experienced): ineffective, frustrated, &dependent


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Welfare for Customers

Customers are rendered dependent Fundamentally Paternalistic

Entire Regulated Public is disabled when

Engaging the Regulatory System

Technology can Mediate between the Naive

User (Customer) & the Expert Regulator


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V&R vs. Usability

Validation & Remediation is Labor intensive

Tools are helpful but not lights out

Domain Expertise is essential Requires Business/Process Owners

Workflow/Process efficiency

Usability has to be the Objective Workers & Customers alike Benefit

Efficiencies yield a huge profit


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Professional Management

IT needs to employ workflow that demands

usability over expedience

Not naive, but do you want it right or right

now? (PeopleFirst & Aspire) The key to career success: only working on

3 year projects for 2 years

We know how to professionally manage, just

need to be allowed to do it

Its the Key to ROI


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Example 1

Visually impaired worker with a grotesquelyinefficient application


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Example 2

Knowledge management applied to regulatory(licensing) portal


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Laws & Standards Addendum

The following 12 slides summarize the majorapplicable Laws pertaining to Accessibility


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Dept of Justice ruling (9/9/96): ADA

accessibility requirements apply to Internet web pages(10NDLR 240)

Central issues focus on:

Effective Communication and

Public Accommodation.Covered entities under the ADA are required to provide effective communication,

regardless of whether they generally communicate through telecommunication devices, printmedia, audio media, or computerized media such as the Internet. Covered entities that use theInternet for communications regarding their programs, goods, or services must be preparedto offer those communications through accessible means as well.- Department of Justice

Laws & Standards Addendum 1.


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Section 504 of the Rehabilitation Act It was the first civil rights legislation in the United States designed to protect

individuals with disabilities from discrimination based on their disability

status.

The nondiscrimination requirements of the law apply to employers and

organizations that receive federal financial assistance. This statute was

intended to prevent intentional or unintentional discrimination based on a

person's disability.

The message of this section is concise; Section 504, 29 U.S.C.794, states:

No otherwise qualified individual with a disability in the United States...

shall, solely by reason of her or his disability, be excluded fromparticipation in, be denied the benefits of, or be subjected to

discrimination under any program or activity receiving Federal financial

assistance.



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Section 508 of the Rehabilitation Act This section requires the Federal government to procure electronic

and information technology (E&IT) goods and services that are not

fully accessible to those with disabilities.

Provides the legislative language and standards for the design of

accessible electronic information technology. (effective: June 21,

2001)

Section 508 is important because: It provides the first federal accessibility standard for the Internet.

It provides compliance language that can be automated and monitored at

a distance.

State governments can be held accountable under the Assistive

Technology Act of 1998.

Businesses must comply with Section 508 when supplying Electronic

and Information Technology goods and services to the federal

government.



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Assistive Technology Act of 1998

Section 101(e)(3) of the Assistive Technology Act of

1998 (AT Act) requires that States receiving AT Actfunds must also comply with Section 508 and the

standards. To gain access to this funding, each state must

assure the federal government they will implement all

conditions of Section 508 within their state entities

(including higher education).

WebAim, 2004; ITTATC, 2005



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47 CFR 6.1 6.23, & 47 CFR 7.1 7.23 Manufacturers

and providers of voicemail and interactive menuservices and products are reminded of their obligations

to take the appropriate measures to ensure that their

products and services are accessible to and usable by

persons with disabilities.



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This was the first product design law to attempt to

drive the market to create accessible products. 36 CFR 1193.37 "Information Pass-Through" requires

telecommunications equipment and customer premises

equipment to pass through codes, translation protocols, formats

or other information necessary to provide telecommunications

in an accessible format.

36 CFR 1193.39 "Prohibited Reduction of Accessibility,

Usability and Compatibility" and provides that no change shall

be undertaken which decreases or has the effect of decreasing

the net accessibility, usability, and compatibility of

telecommunications equipment or customer premises

equipment.



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Florida Accessible Electronic &Information Technology Act of 2006 Became law July 1, 2006

Legislation was one of the recommendations of the

A-eIT Task Force

Creates part III of Section 282, F.S. (HB 1503, SB 2012)

Applies to the executive, legislative and judicial branches of state

government

Tracks Section 508 federal language Requires agencies to use Section 508 1194 standards for procuring,

developing, and maintaining A-eIT



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Florida Accessible Electronic &Information Technology Act of 2006 Requires the Department of Management Services to

work with stakeholders to create administrative rules.

Provides for undue burden and exemptions similar toSection 508 at the federal level Undue burden:

Follows Section 508 federal standards requiring documentation

Requires provision of alternate access to information and data thatprovides equivalent use

Exemptions include:

Department of Military Affairs and the FL National Guard

Criminal Intelligence Activities

Contractor EIT acquired incidental to a state contract



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Florida Accessible Electronic &Information Technology Act of 2006 Applies to competitive solicitations issued and new

systems developed after July 1, 2006 Allows the state to use the body of federal law and related

interpretations in regard to the administration of this Act.



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Section 508 Accessible Electronic &Information Technology Standards

Subpart B -- Technical Standards

1194.21 Software applications and operating systems. 1194.22 Web-based intranet and internet information

and applications. 16 rules.

1194.23 Telecommunications products.

1194.24 Video and multimedia products. 1194.25 Self contained, closed products.

1194.26 Desktop and portable computers.



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Subpart C -- Functional Performance Criteria

1194.31 Functional performance criteria. People with visual impairments

People who are deaf or hard-of-hearing

People with speech impairments

People with motor impairments



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Subpart D -- Information, Documentation, and

Support 1194.41 Information, documentation, and support.

Product support in alternate formats

Descriptions of accessibility and compatibility features in

alternate formats Product support services in alternate communications modes


usability trumps accessibility

Documents