CAPED PreConference Workshop

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(No Transcript)
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CAPED Pre-Conference Workshop

• Accessibility of Electronic and Information
  Technology
• October 24, 2004

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Presenter Information

• David Baquis
• Accessibility Specialist Technology
• Background blends experience in 4 areas
• Consumer information
• Technology
• Disability issues
• Public Policy

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Audience Check

• Education sector?
• Industry sector?
• Government sector?
• Consumer sector?
• Who has read the 508 standard?

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Agenda

• 1.    Opening Remarks
• 2.    Accessibility
• 3.    Introduction to 508
• 4.   508 Basics
• 5. Technical Requirements (overview)
• 6.    Section 255
• 7.    University Accessibility
• 9.   Rulemaking and the Board
• 10.  Resources
• QA

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Speaking Up in Todays Session

• Ok to ask questions as we go along
• Please use microphones for accessibility/usability
  
• Please say who you are and keep it brief
• I will put people in queue if we get several hands

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Part 1

• Opening Remarks

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How is 508 Going?

• Measuring impact anecdotal
• Improvements in product designs
• Industry involvement - tip of the iceberg
• Web accessibility focus has been excluding other
  products
• Contract requirements confusion
• Staff turnover issues pros and cons

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Success in Implementationof 508 Procurement
Policy

• The Section 508 Steering Committee is considered
  one of the most successful federal interagency
  collaborative efforts.
• The Federal Information Technology Accessibility
  Initiative is a model for outreach. The 508
  Working Group recently received an e-gov award.

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Whats Next?

• Incorporation of buy accessible practices in
  society
• Open use of Buy Accessible Wizard at
  http//www.buyaccessible.gov
• One day perhaps a landmark complaint
• Efforts toward international harmonization of
  standards

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You Dont Have to be an Expert

• Know the difference between the law and the
  standard
• Know how to ask good questions to the vendor
• Use the Buy Accessible Wizard to generate
  requirements
• Know different types of technical assistance
• Learn from others experiences
• Pull together all the stakeholders in your team

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Practical Questions for Product Evaluation

• 1.) Is the product EIT?
• 2.) What provisions of the 508 Standard apply to
  the product?
• 3.) What features of the product support the
  applicable provisions.
• Note -many products conform to some, but not
  all, applicable provisions. That is why it is
  generally not appropriate to ask a yes/no
  question about whether a product is fully
  conformant.
• 4.) How did you test the product for
  508-conformance?
• 5.) How do you meet you 255 requirements?
  (telecom)

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Part 2

• What is Accessibility?

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Terminology

• Accessibility of a product
• Accessible situation to a person
• Accommodations improve access, but should not be
  confused with accessible features of mainstream
  technology
• Compatibility with assistive technology
• Compatibility with mainstream technology
• The 508 Standard sets a minimum requirement for
  accessible design. Some products can be enhanced
  with usability improvements.

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Usability makes it easier to use
technology.Accessibility makes it POSSIBLE to
use technology.Don Barrett
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Open Architecture

• Designing for compatibility
• Electronic curb cut analogy
• 508 does not require an IT product to
  interoperate with every brand and model of AT on
  the market
• Design to the Standard, not to the skill level of
  the person

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What is the Difference Between Accessibility and
Accommodation?

• Accessibility is technology-centered.
  Accommodations are person-centered.
• Accessibility occurs before the fact.
  Accommodations happen after the fact.
• Accessibility focuses on mainstream technologies.
  Accommodations primarily focus on assistive
  technologies.

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Complementary Nature of Assistive Technology and
Information Technology

• AT Hearing aids
• IT Telephone handsets/receivers
• AT TTYs
• IT IVR/Voicemail/Auto attendant systems
• AT Computer assistive software or hardware
• IT Display of Caller ID and similar functions

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Difference Between Compliance and Conformance

• Compliance pertains to the law and may apply to
  entities such as agencies, people, companies and
  organizations
• Conformance pertains to the technical design
  standards or guidelines and applies to products
• This distinction allows the covered entity be
  compliant in their procurement process, even if a
  product is not totally conformant with the
  Standard (by claiming an allowable exception).

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Why Regulate Accessibility?

• Regulation helps ensure accessible design
  natural market forces do not normally address
  accessibility
• Business case increase customer base
• Doing the right thing helps reduce liability
• Federal government is a model employer
• Secondary benefits accessibility may increase
  usability

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Evolution of (some) FederalDisability Policies

• Architectural Barriers Act
• Rehabilitation Act (Sections 501, 504, and 508)
• Americans with Disabilities Act
• Telecommunications Act (Section 255)
• Assistive Technology Act (amended)
• HAVA

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Part 3

• Introduction to 508

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What is Section 508?

• It refers to the law
• It also refers to the design Standard issued by
  the Access Board
• FAR incorporated the Standard

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History of Section 508

• Originally added to the Rehabilitation Act of
  1973 in 1986
• Amendment to Section 508 signed into law
  on August 7, 1998
• In July of 2001, the Federal Acquisition
  Regulations added the Section 508 Standard to the
  regulations that Federal agencies must follow
  when procuring EIT products

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Comparable Accessis the Spirit of 508

• Section 508 applies to all Federal agencies when
  they develop, procure, maintain or use electronic
  and information technology.
• When a Federal agency or department performs any
  of the above functions involving electronic and
  information technology, they must ensure that
  employees with disabilities and members of the
  public have comparable access to information and
  data to that experienced by non-disabled
  employees.

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What is the Purpose of 508?

• Ensures that people with disabilities are not
  left behind in the information age.
• Increases prospects for people seeking Federal
  government and improves job functions for current
  Federal employees.
• Enhances usability of Federal EIT for the public
  by reducing barriers to full productivity by
  people with disabilities.

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Why is 508 Important?

• Promotes independence proactively. In some
  cases, users need not self-identify and request
  accommodations.
• Supports employment of people with disabilities
• Enhances availability of Federal government
  information services and products to the public
• Encourages improvements in accessible design
• Indirectly increases availability of accessible
  products everywhere
• Raises awareness of disability issues. Private
  sectors incorporate 508 as guidance in strategic
  planning.

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Why was Section 508 needed? Disability
Demographics

• 20.6 -- or 54 million persons in the United
  States have some level of disability
• Over 70 of working age persons with severe
  disabilities have minimal or no employment
• The Federal government currently employees about
  167,900 persons with disabilities

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Why was Section 508 needed?- Internet Users

• According to a UCLA Report, by 1997, some 19
  million Americans were using the Internet
• That number tripled in one year, and then passed
  100 million in 1999
• In the first quarter of 2000, more than five
  million Americans joined the online world,
  roughly 55.000 new users each day

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Why was Section 508 needed?- Increased Reliance
on E-mail

• More than two-thirds of Americans have some type
  of access to the Internet. In less than a decade,
  e-mail has become a fundamental communication
  tool
• In 1998, the U.S. Postal Service delivered 101
  billion pieces of paper mail estimates of the
  number of e-mail messages transmitted that year
  range as high as four trillion
• The number of electronic mailboxes worldwide
  reached almost 570 million in 1999

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Why was Section 508 Needed?- Web Use

• Every 24 hours, the content of the Worldwide Web
  increases by more than 3.2 million new pages and
  more than 715,000 images
• In late 2002, the total number of hits on U.S.
  web pages passed the one billion per day mark
• Section 508 will significantly impact those who
  have historically had the most information access
  barriers

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What Does Section 508 Require?

• Federal agencies must ensure that electronic and
  information technology is accessible to employees
  with disabilities and to members of the public to
  the extent it does not pose an undue burden to
  the agency
• Undue burden is a high standard to meet
  (significant difficulty or expense)

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What Else is Required?

• A report is required every two years by the
  Department of Justice on the status of electronic
  and information technology accessibility in the
  Federal government
• The first report was issued in 2000 and the
  second report was issued in 2004.

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Who is Covered by 508?

• The law applies to Federal agencies and
  departments
• The term federal agency or department is
  defined in the CFR (Code of Federal Regulations)
• 508 does not cover legislative or judicial
  branches, although some take initiatives toward
  voluntary accessibility.
• The 508 Standard can be used as guidance by
  state and local governments and educational
  institutions
• The Federal Acquisition Regulations (FAR) apply
  only to the Federal sector
• 508 is not a direct requirement of vendors

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Part 4

• 508 Basics

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Whats the difference?

• Statute (law)
• Guidelines
• Government standards (enforceable)
• Voluntary consensus standards

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Basic Contents of the Section 508 Standard

• Preamble (Hint read this part last)
• Subpart A General
• Subpart B Technical provisions
• Subpart C Functional performance criteria
• Subpart D Documentation and support

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What is EIT?(And why is this question
important?)

• Definition of electronic and information
  technology Any equipment or system or subsystem
  that is used in the automatic acquisition,
  storage, manipulation, management, movement,
  control, display, switching, interchange,
  transmission or reception of data or information
• Key term principle function
• Is a computer microchip EIT?
• Is a microwave oven EIT?
• Is email covered by 508?
• What about a web-based subscription service?

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Some Exceptions Available Under Subpart A of 508

• Lack of commercial availability
• Fundamental alteration
• Technology incidental to a Federal contract
• Back office (must meet both architectural as well
  as usage criteria)
• National security (Active duty armed forces
  personnel are not members of public or Federal
  employees.)
• Note that Federal agencies are the only ones who
  can claim exceptions regarding their
  procurements, not vendors.

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Subpart C in a Nutshell

• Describes disabilities addressed, but does so
  with functional requirements, such as usable
  with no vision.
• Describes TWO approaches to accessibility
  Built-in and compatible design.
• The provisions in this section require products
  to either fully accommodate the needs of people
  with disabilities, or the product must be
  compatible with the assistive technologies used
  by people with disabilities.

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Disabilities AddressedUnder 508 Subpart C

• Vision
• Dexterity
• Hearing
• Speech (often overlooked in articles about 508)

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Subparts B versus C Which Provisions to Use and
When

• When requesting and evaluating products, use B
  first and then look at C, to see if you missed
  any functions
• Dont ask What category does the product fall
  in?
• Instead ask What functionality does it
  feature?
• Consider convergence e.g. touch screen cell
  phone keypad
• 508 trumps as deciding factor best meets (Must
  buy most accessible - presumes all else being
  equal and not forgoing other essential business
  requirements)

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Equivalent Facilitation

• Can be used by a vendor as a design option for
  meeting or exceeding 508-conformance requirements
• The solution must provide substantially
  equivalent or greater access to and use of a
  product for people with disabilities.
• Often mistakenly confused with accommodations. It
  cannot be used as a basis for excusing poor
  accessible design.

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What Does Subpart D Require?

• 1.) Documentation in alternate formats (in cases
  where documentation is provided).
• The federal agency is responsible for this, not
  the vendor, unless the agency requires it in
  their contract. In that case it is considered an
  additional agency requirement, not a 508
  requirement.
• The vendor can provide an electronic
  (convertible) version to help the agency meet
  it's requirements.
• 2.) Description of accessibility and
  compatibility features.
• 3.) Support services shall accommodate
  communication needs of end users with
  disabilities.

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What Remedies are Available Under 508?

• Section 508 provides remedies to employees of
  Federal agencies and members of the public who
  are aggrieved by violations of its requirement.
• Complaints should be filed with the Federal
  department or agency alleged to be in
  non-compliance. Complaints are handled via
  Section 504 administrative procedures.
• Individuals can file private rights of action in
  court.
• What is a person of standing?
• Injunctive relief is the fix, not punitive
  damages.

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Part 5

• 508 Technical Requirements

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Types of Products Covered Under 508 (Subpart B)

• Software applications and operating systems
• Web-based intranet and internet information and
  applications
• Telecommunications products
• (What is a two-way conversation?)

• Video and multimedia products
• Self contained, closed products
• Desktop and portable computers

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3 Types of Access

• Communication access
• Information access
• Physical access

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Examples of RequirementsTelecommunications
Products

• Support for TTY code
• VCO/HCO support
• Pass-through of TTY signals
• TTY usability of IVR, auto attendant, and voice
  mail
• Direct connection point
• Support intermix of voice and TTY

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Examples of RequirementsTelecommunications
Products

• Amplification
• Auto reset of volume
• Hearing aid compatibility
• Minimized Interference

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Examples of RequirementsTelecommunications
Products

• Caller ID and similar functions
• Response time warning and
• means of extension

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Examples of RequirementsTelecommunications
Products

• Tactile discernability
• One hand use no tight grasping, pinching, wrist
  twisting
• Key repeat
• Status of locking toggle controls or keys

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Examples of RequirementsSoftware Applications
and Operating Systems

• Keyboard equivalents
• Provide current focus
• User interface element
• Dont disrupt accessibility features with an
  installation
• Color contrast

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Examples of RequirementsWeb-based Intranet and
Internet Information and Applications

• A text equivalent for non-text elements
• Captioning and AD for multimedia presentations
• Electronic forms designed to be completed on-line
  usable by assistive technology users.
• Alternatives to color for distinguishing elements
• Time-out warning

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Examples of RequirementsVideo and Multimedia
Products

• Hardware requirements (TVs and computers with
  tuners)
• Captioning decoder chip
• SAP playback circuitry
• Production requirements (when indicated)
• Captioning and Audio description
• What does multimedia refer to?
• What is content essential for comprehension?
• What is a training and informational video that
  supports an agencys mission?
• Significance of term regardless of format
  (Example of DVD with video content versus
  document content)

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Examples of RequirementsSelf Contained, Closed
Products

• Usable without requiring attachment of AT
• Tactilely discernable keys when touch screens
  used
• Status of locking controls/ keys when touch
  screens used - visually discernable, and
  discernable either through touch or sound
• Alternative form of identification or activation
  when biometric ID is used
• Operable controls reach issues

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Examples of RequirementsDesktop and Portable
Computers

• Where a product utilizes touchscreens or
  contact-sensitive controls
• Usable with one hand and without not requiring
  tight grasping, pinching or twisting of the
  wrist, when touchscreens are used
• Key repeat adjustability, when touchscreens are
  used.
• Where provided, at least one of each type of
  expansion slots, ports and connectors shall
  comply with publicly available industry
  standards. (For AT compatibility)

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Part 6

• Sections 508 and 255

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What is the Difference Between 508 and 255?

• A little Access Board humor

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508 versus 255Two Different Laws

• A section of what??
• Section 255 of the Telecommunications Act of 1996
• Section 508 of the Rehabilitation Act of 1973, as
  amended in 1998

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508 and 255Driving Accessibility

• Together require the design (255) and procurement
  (508) of accessible telecommunications products.
• Economics of pushing and pulling accessibility
• Both encourage improvements in accessible design
• Both harmonize existing standards

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Two Drivers of Accessibility
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Examples of Accessibility Features in a Telephone

• Volume control
• Tactile discernability of controls and keys
• Alternative output for screen information
• Ease of docking a cell phone into charger

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508 versus 255Entities Covered

• Section 255 Telecommunications manufacturers and
  service providers (regarding accessible design)
• Section 508 Federal agencies and departments
  (regarding compliant procurements)

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508 versus 255Products Covered

• Section 508 electronic and information
  technology
• Generally broader
• Section 255 telecommunications products and
  services
• Seems narrower, unless systems are convergent
• Most procurements are complex, not simple

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Examples of Products Covered Under 255

• Section 255gt (narrower scope)
• Telecommunications products include
• Wireline and wireless telephones
• Pagers
• Fax machines (some but not all)
• Voicemail and interactive menu functions
• Equipment not coupled directly to the network,
  such as a computer that is connected to a PBX

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Potential Complexityof Procurements

• In determining which requirements apply to a
  telecom system, consideration should be given
  to all the possible product components
• Telecom hardware
• Computers to drive a PBX system
• Software to run in the computer
• A video to explain how to use the product
• A website that updates audiotext IVR information

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508 versus 255Differences in Disabilities
Addressed

• Section 508
• Hearing
• Speech
• Vision
• Dexterity

• Section 255
• Hearing
• Speech
• Vision
• Dexterity
• Cognition

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508 versus 255Company Processes

• Under 255, not only are telecommunications
  manufacturers and service providers required to
  provide accessible products and services, but
  they must also
• Consider accessibility in all phases of their
  design process
• Collaborate with disability organizations
• Include people with disabilities in the testing
  and marketing of their products
• Section 508, on the other hand, focuses on
  outcomes procurements of conformant products.

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508 versus 255Differences in Degree of Effort
to Comply

• Section 255 ..when readily achievable to do
  so (weaker)
• Section 508 ..unless and undue burden would be
  posed upon an agency. (stronger)

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508 versus 255Enforcement Mechanisms

• Section 255 Federal Communications Commission
  has a broad range of investigative and remedial
  powers. (No recourse in court)
• Full range of enforcement mechanisms available
  including investigations, hearings, citations,
  forfeitures, and settlement talks.
• Informal complaints consumer friendly, fast and
  effective.
• Focus is on getting accessible products into the
  marketplace.
• Section 508 Administrative complaint process
  (Section 504) of each agency and department.
  Also, individuals have a right to file a private
  civil action.

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Why Dont People Complain?

• They are afraid of making trouble for an
  employee, a company or themselves.
• They are so upset, they are afraid of the
  intensity of their feelings.
• They believe that some other person or
  organization is handling it and the issue will be
  resolved through them.
• They think their complaint will be ineffective.
• They dont know the proper complaint procedure.
  (See Speak Out Guide from ITTATC)
• Enforcement problem No watchdog. Both 255 and
  508 are complaint driven

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Part 7

• University Accessibility Initiative

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What Types of EIT Might be Owned by a University?

• Websites
• Telephone systems, including phones and IVRs
• Information kiosks
• Computers
• Software
• Video productions
• Multimedia hardware, such as TVs
• Copiers, printers and fax machines
• Is training or distance e-learning considered
  EIT?

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Making the Case (Using Carrots rather than
sticks)

• Supports employment of staff with disabilities
• Supports students with disabilities in school
• Supports community participation in activities
• Accessibility improves usability in some cases
• Good public relations
• Prepare now for future regulations
• What if accessibility was not expensive or
  difficult to implement? - Essential to act on
  facts, not assumptions

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Where is the University EIT Located?

• Classrooms
• Libraries and Cafeterias
• Academic department and Administrative offices
• Student activity centers and sports arenas
• Laboratories and research centers
• Off campus teaching sites in the community
• IVR system virtually available to everyone
• Mobile (wireless) products
• Internet websites virtually available to everyone

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Who are Stakeholders of Accessible EIT in
Education?

• People with disabilities
• Students
• Teachers
• Support/administrative staff
• Parents/guests
• All citizens who obtain Internet info from
  colleges or call the telephone system
• People of all ages and parts of the world

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Template for Implementation

• Identify purchasers and developers on all levels
• Involve people with disabilities in all stages of
  the process
• Respect organizational culture (e.g.,
  decentralization)
• Assign responsibility and authority to department
  liaisons
• Establish checks and balances
• Plan for continual training
• Design automation into accessibility (e.g. web
  authoring)
• Set priorities What EIT is most essential and
  which is used most often? Use a timeline and set
  deadlines.

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What is an Accessibility Initiative?(Going the
extra mile)

• Buy-in from top down (Statement of commitment
  from the Board)
• Establish accessibility policy (Needs to be well
  crafted)
• Connect the dots (Tie accessibility to existing
  policy about welcoming diversity PWDs are the
  largest minority group)
• Empower a director to manage the program
• Create an internal advisory committee (working
  group) and an external advisory council of
  experts
• Incorporate EIT accessibility into university
  strategic plan
• Marketing website, open house, publications,
  speeches, etc
• Creativity - Sponsor an accessibility award
  competition

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Institutionalizing Accessibility

• Set a goal to raise awareness of students, staff
  and other users about accessibility.
• Many academic departments, for example, could
  integrate teaching of accessibility issues into
  their curriculums
• Highlight accessibility success stories
• But please dont confuse them with accommodations
• Best practices need to be shared between
  institutions and among departments

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What can you do?

• A letter of appreciation goes a long way
  Support the industry champions.
• Dont just complain to associates and settle.
• Gently inquire - as a systems change strategy
• - How many TTY accessible IVRs do you know of?
• Plan how you will evaluate products for
  accessibility.
• The number one way to advocate for accessibility
  is to actually use the technology!
• Teach accessibility in classes

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Part 8

• Rulemaking and the Access Board

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What is the Access Board?

• Independent Federal agency
• Creation authorized under the Rehabilitation Act
  of 1973
• Mission promote accessible design for persons
  with disabilities
• Official board of 25 members
• 13 public members appointed by the President for
  4-year terms
• 12 members from various Federal agencies
• Meets every other month

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Responsibilities of the Access Board

• Develop and maintain accessibility requirements
  for the built environment, transit vehicles,
  telecommunications equipment and for EIT
• Provide technical assistance and training on
  these guidelines and standards
• Enforce accessibility standards for federally
  funded facilities

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Staff of the Access Board

• Approximately 30 employees
• 5 million budget
• 3 organizational units
• Office of the Executive Director
• General Counsel
• Technical and Information Services
• Support research (small budget). Examples
• Assistive listening systems
• Information kiosks
• Interference to hearing technologies (ICDR funded)

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What is the Access Boards Role in 508?

• Congress assigned responsibility to the Access
  Board to develop accessibility standards for EIT
• The Board is also required to periodically review
  and amend the standards to reflect technological
  advances or changes to EIT (No plans to do that
  anytime soon!)
• Technical assistance and training on the Standard
  is required.

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508 Rulemaking

• Advisory Committee involvement 27 members
  representing industry, disability organizations
  and other groups
• Based on consensus where possible
• Information meetings with extensive public input
• Open and inclusive process NPRM in Federal
  Register over 100 comments submitted

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Incorporation of Other Rules into the 508
Standard

• Rehabilitation Act
• Americans with Disabilities Act
• Telecommunications Act
• Hearing Aid Compatibility Act
• Television Decoder Chip Circuitry Act
• International harmonization The impact of 508 is
  being seen around the world

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What was the Access Boards Role?

• In March 2000, The Board published proposed
  standards based on the EITAACs recommendations
• The proposed standards were available for public
  comment through publication in the Federal
  Register
• Over 100 individuals and organizations submitted
  comments on the proposed standards
• Final standards were published on December 21,
  2000

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The 508 StandardFinal Requirements

• The Access Board, after consulting with Federal
  agencies, industry, and disability organizations,
  published standards setting forth
• 1.) a definition of electronic and information
  technology
• 2.) technical and functional performance criteria
• Section 508 is not about assistive technology
  its purpose is to improve access to mainstream
  technology Thus making it easier to use
  assistive technology.

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Technical Assistance and Training(Data from 2003)

• Since issuing the 508 Standard in 2000
• We responded to over 14,000 technical assistance
  inquiries
• Our website averaged 75,900 user sessions and
  over 700,000 hits per month
• We conducted over 140 training sessions and
  reached a collective total audience of
  approximately 11,000 people
• We mailed out approximately 6,000 packets of
  information to our customers

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Part 9

• Where can I get more information?

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How to Reach the Access Board

• Toll-free
• 800-872-2253 (voice) or 800-993-2822 (TTY)
• Internet http//www.access-board.gov
• E-mail 508_at_access-board.gov

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Access Board Section 508 Website Technical
Assistance

• Guides on each technical area of Subpart B
• Interactive courses on technical areas of
  Subpart B
• Tutorial on software design
• Tutorial on accessible telecommunications product
  design
• 508 Standard posted in English, Spanish, Japanese
  and digital talking book formats
• Overview and background, as well as tri-fold
  brochure
• Links to the statute, the FAR, section508.gov,
  e-learning, ITTATC and others.

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Helpful Federal Agency Websites

• http//www.section508.gov (Federal Information
  Technology Accessibility Initiative)
• http//www.usdoj.gov/crt/508 (Department of
  Justice 508 page)
• http//www.fcc.gov/crb/dro/ (Federal
  Communications Commission Disability Issues Page)
• http//www.icdr.us (Interagency Committee on
  Disability Research) Results of workshop on
  interference to hearing technologies (pending)

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Additional Federally Funded Sources of
Information

• Disability and Business Technical Assistance and
  Training Centers (www.adata.org/dbtac.html)
• Information Technology Technical Assistance and
  Training Center (www.ittatc.org)
• National Center on Accessible Technology in
  Education (www.washington.edu/accessit)
• State Assistive Technology Programs
  (www.resna.org and activate link list of ATPs)
• Interactive Voice Response Systems Accessibility
  Forum (www.atis.org/atis/ivr/ivrhom.htm)

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Pacific ADA IT Center

• Pacific Disability and Business Technical
  Assistance Center (Pacific DBTAC)ADA Hotline
  1-800-949-4232www.pacdbtac.org email
  adatech_at_pdbtac.com555 12th Street. Suite
  1030Oakland, CA 94607-4046

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Part 10

• Questions?

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Sample FAQs

• I dont have a 508 situation in my office, OK?
• Do I have to replace all my infrastructure now?
• Can I exempt my whole agency due to homeland
  security?
• Can I buy a product that is not fully accessible?

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More FAQs

• Does a college have to comply with 508 LAW
  because it receives federal funding?
• Is training or distance e-learning considered
  EIT?
• Question How to make a teleconference
  accessible?
• Is there a list of 508-certified products?
• Whose responsibility is it to determine
  conformance?