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While it may seem that Section 508 compliance is daunting because of the range of activities it covers, a simplified look at the pieces reveals how to fit it into a Postal Service business solution.
Step 1. Learn About 508.
To learn about Section 508 requirements, see the following sources:
• HBK AS-508-A, Section 508 Technical Reference Guide.
• Postal Service Intranet or Internet search on Section 508.
• Purchasing Manual, http://blue.usps.gov/cpim/manuals.htm.
• EIT Accessibility Standards (includes a definition of EIT):
• http://www.access-board.gov/508.htm
The Goal —
Make text and data as accessible to people with disabilities as it is to people without them.
Step 2. Determine whether EIT is part of the business solution.
• If EIT is not part of the business solution, Section 508 does not apply. Skip the remaining steps and continue with the normal purchasing process.
• If EIT is part of the solution, determine whether a general exception applies. If a general exception is justified, document the exception and include it in the contract file.
Step 3. Identify the applicable EIT standards and then conduct market research to determine if there are EIT solutions that meet business needs and address the standards.
• Section 508 defines six technical standards, which include many provisions. Keep the following in mind:
• Some functions are defined by a single standard.
• Some functions may be covered by multiple standards.
• Research products and services that meet business needs and learn about their Section 508 compliance.
• Look for the product's Voluntary Product Accessibility Template (VPAT). Many suppliers are using this form to provide information on how they conform to the Section 508 standards. If no VPAT is available, ask the supplier to produce a VPAT or provide comparable documentation.
• Search the Internet and supplier Web sites.
• Contact other government agencies that are already using the product or service.
• Determine if an exception applies (e.g., no product exists that complies with the applicable standards and meets the business requirements). If an exception exists, document it appropriately.
Step 4. Include "Section 508" clauses in the Statement of Work (SOW)
Once market research is complete, work with Supply Management to do the following:
• Develop a solicitation that correctly states Section 508 requirements.
• Determine in the evaluation process if there should be any special instructions to suppliers.
• Include "Section 508" concepts in the internal design or implementation documents.
Step 5. Evaluate and test products based on "Section 508" standards
Evaluation and selection activities are key components in positioning the Postal Service to meet its Section 508 compliance commitments. In evaluating and testing products, follow these guidelines:
• Compare supplier responses that meet Section 508 requirements.
• Determine how to evaluate and test suppliers' proposed solutions for compliance. This varies, depending on the complexity of the solution. There are different ways in which proposed solutions can meet the requirements. For information on exceptions and undue burdens, see section 4-3 of this handbook and section 4-6 of Handbook AS-508-A, Section 508 Technical Reference Guide.
• For products that do not fully conform, a specific exception may be needed (see section 4-3).
• Conduct testing and evaluation, which may include the following:
• Demonstrations by the supplier.
• Testing by the Postal Service or third-party suppliers.
• Literature evaluation.
Proof of Compliance —
If your product provides at least one mode of operation and retrieval that does not need user vision, hearing, or fine motor skill or provides support using assistive technology, it is compliant.
Step 6. Plan Delivery
Before delivery of a solution, an acceptance test is a standard procedure to verify that the supplier has met its contractual obligations. The Postal Service can conduct and may require the contractor to perform Section 508 testing with multiple techniques. See the resources in the technical reference guidelines for recommended approaches. Before accepting a purchase, do the following:
• Test compliance with the stated accessibility standards.
• Work with the vendor to address issues where the vendor does not meet standards.
• Work with Supply Management to address the issue, if the deliverable does not meet standards.
The Measure of Success -
Success is measured by compliance at the text or data "interface," (i.e., where the person with a disability can access information).
Section 508 includes six technical standards with associated provisions and functional performance criteria.
These technical standards are defined in terms of classes of technology (i.e., software applications and operating systems; Web-based intranet and Internet information and applications; telecommunications products; video and multimedia products; self-contained, closed products; desktop and portable computers). These technical standards translate into day-to-day business functions such as using the Web to look up postal rates, using a kiosk to purchase stamps, getting messages with e-mail, and using a computer to view a presentation.
The Functional Performance Criteria define overarching performance measures that ensure interaction across all classes of technology. They ensure that, from the perspective of a person with a disability, all interactions are consistent and accessible, regardless of the class of technology.
Business functions often span multiple classes of technology. When you apply the law, you must consider all applicable technical standards and functional performance criteria. For example, an e-learning system may include Internet-based technology, video and multimedia, and access from a desktop, with consistent functional performance.
When we adhere to both technical standards and functional performance criteria, people with functional limitations can use all IT systems.
There are three types of exceptions that can be invoked and still achieve Section 508 compliance. The three types are general exceptions, specific exceptions, and undue burdens. Definitions of each category of exception may be found in Chapter 4, Section 508 - Postal Service Processes to Comply, of Handbook AS-508-A, Section 508 Technical Reference Guide.
When the purchase of an EIT solution falls within even one of the three exception areas, the Postal Service requires the functional organization to document the rationale for the exception. Supply Management, together with the functional organization, must include the relevant market research documentation in the contract file. For general and specific exceptions, the documentation is relatively easy to prepare. When the purchase of an EIT solution would result in an undue burden to the Postal Service, the requiring organization must prepare an undue burden justification, signed by the vice president of the requiring organization. Additional detail for documenting undue burdens can be found in Chapter 4 of Handbook AS-508-A, Section 508 Technical Reference Guide.