Executive Summary & Recommendations(1)
Introduction
Prior to the late 1980's, computers were generally easy for most people with disabilities to
use. People who were blind, for example, could use the same word processing software
packages as everyone else. Instead of relying on monitors, they used assistive technology --
called "screen readers" -- to read in a synthesized voice all the text and punctuation that a
sighted person would read on the computer monitor. All who used early word processors used
keyboard commands to interact with the software. To print a document, for instance, one would
simultaneously hit the "control" and "P" keys -- something that could be done as easily by blind
people as others.
As technology grew more sophisticated, many changes that generally made it easier for
nondisabled people to use computers often created barriers for people with disabilities. For
instance, software that required someone to issue commands by "pointing and clicking" using a
computer mouse became inaccessible to those who could not see icons. Although the solutions
were simple and inexpensive, little thought was given to preserving accessibility. For example,
if word processing software allows the user to choose between entering "control-P" to print or
clicking on a printer icon, then blind people can use the print function as easily as everyone else.
In the past, most agencies did not focus on the extent to which their mainstream
technology was accessible to persons with disabilities. Some employees with disabilities lost
jobs or became underemployed due to technological advances that unfairly screened them out
from the workplace, even when they otherwise had the skills, intelligence, and knowledge to
accomplish their jobs.
Section 508 of the Rehabilitation Act
An amendment to section 508, signed by President Clinton in August 1998, requires the
Attorney General to report to the President on accessibility of federal electronic and information
technology (EIT) -- such as federal Web sites, telecommunications, software, hardware, printers,
fax machines, copiers, and information kiosks -- to people with disabilities. Section 508 of the
Rehabilitation Act, 29 U.S.C. § 794d, as amended.
Section 508 prohibits federal agencies from procuring, developing, maintaining, or using
EIT that is inaccessible to people with disabilities, subject to an undue burden defense. "Undue
burden" generally means a significant difficulty or expense.
On March 31, 2000, the Architectural and Transportation Barriers Compliance Board
(Access Board) published a Notice of Proposed Rulemaking containing draft accessibility
standards to implement section 508. 65 Fed. Reg. 17346. Once final, these Standards will be
incorporated into the Federal Acquisition Regulation (FAR), to which most agencies are subject.
Agencies not covered by the FAR will incorporate the Access Board's Section 508 Standards
into their own procurement regulations.
The General Services Administration (GSA) and the Access Board share statutory
authority to provide section 508 technical assistance. 29 U.S.C. § 794d(b).
Although the law technically applies to federal agencies' existing EIT, by its own terms it
is unenforceable except for products procured on or after August 7, 2000; retroactive
modification of existing EIT is not required. Agencies continue to have long-standing
obligations under sections 501 and 504 of the Rehabilitation Act to provide reasonable
accommodations to qualified individuals with disabilities (including members of the public and
federal employees) upon request and to avoid disability-based discrimination, generally. 29
U.S.C. §§ 791, 794. Agencies must comply with section 508 regardless of whether they have
employees with disabilities or serve members of the public with disabilities.
Built-in assistive technology is not required where it is not needed. Section 508 does not
require every workstation or every EIT product to be fully accessible to persons with disabilities.
Products like desktop computers do not have to be outfitted with refreshable Braille displays;(2)
rather they must be compatible with refreshable Braille displays, so that if an individual who is
blind needs one as a reasonable accommodation, he or she can use it with the agency's standard
workstations.
Section 508 does not require private companies who market EIT products to the Federal
Government to modify the EIT products used by company employees, or to make the companies'
own Internet sites accessible to people with disabilities. For instance, if a manufacturer wishes to
sell desktop computers to federal agencies, it must ensure that these computers comply with the
Access Board's Section 508 Standards or agencies will be unable to purchase them. The
company telecommunications systems, Internet pages, and other EIT used by company
employees (including desktop computers not intended for federal use), are not subject to section
508.
The Department of Justice is not charged with enforcing section 508. Members of the
public and employees with disabilities, however, may:
- file administrative complaints with agencies they believe to be in violation of
section 508; or
- file private lawsuits in Federal district court.
29 U.S.C. § 794d(f).
In August 2001 and every 2 years thereafter, the Attorney General is required to provide
updated reports to the President and Congress. These subsequent reports will discuss
improvements in the degree of accessibility of federal EIT and will also report on the resolution
of section 508 complaints filed against federal agencies. 29 U.S.C. § 794d(d).
The Report
The Department of Justice's Civil Rights Division has prepared this Report. It contains
the results of the first Executive Branch-wide section 508 evaluation. It also recommends
specific inexpensive, cost-effective, and easily accomplishable measures to improve the extent to
which federal agencies' technology is accessible to people with disabilities. By following these
recommendations, agencies will facilitate their compliance with the general nondiscrimination
and reasonable accommodation requirements of sections 501 and 504 of the Rehabilitation Act.
The Department's recommendations make the most of existing resources and build upon model
agency practices.
The Report is intended to provide guidance to:
- federal information technology personnel, policy makers, and procurement
officials,
- private sector technology designers, manufacturers, and vendors, and
- disability advocates.
History of the Department of Justice's Efforts
In April 1999, the Attorney General sent a package of detailed self-evaluation materials
and resource guides to federal agencies and departments, including the U.S. Postal Service, to
assist them with accomplishing meaningful section 508 self-evaluations. Agencies were
instructed to evaluate their procurement policies and practices, telecommunications products and
systems, and their most commonly used Internet pages, software applications, information kiosks
and other information transaction machines, and other electronic office equipment such as fax
machines, copiers, and printers. Products were generally evaluated in 2 ways:
- using objective checklist-style questions, and
- using more subjective evaluation techniques, such as consulting with people with
disabilities and viewing Internet pages with text-only browsers and other types of
assistive technology.
To create this Report, the Department collected objective survey data from 81 agencies,
including over 250 components, on an interactive Internet database site. A list of these agencies
is attached as General Appendix A (Categories of Agencies). Subjective "overall agency
evaluations" were also provided to the Department.
The Department established a section 508 home page (http://www.usdoj.gov/crt/508) to
make available to a wide audience the Department's section 508 resource guides and self-evaluation material. Federal and state agencies, the technology industry, and disability advocates
regularly use this web site. From the week ending April 12, 1999, through the week ending
March 13, 2000, we recorded 201,432 "hits" on this site.
For the last 18 months, representatives of the Department of Justice have met with
countless agencies to help them understand the importance of section 508 and to assist them with
their self-evaluations.
This Report would not have been possible without assistance from the Department of
Education, the General Services Administration, the Federal Communications Commission, and
other agencies. The Department also learned from private sector leaders in the field of
technology accessibility, including the World Wide Web Consortium's Web Accessibility
Initiative and the University of Wisconsin's Trace Center.
General Findings and Recommendations
While several agencies are models of accessibility, the data suggest the need for
improvement in the accessibility of federal EIT to persons with disabilities. Most agencies can
also improve the extent to which disability accessibility issues are incorporated into their
mainstream technology procurement contracts.
The most significant challenge posed by section 508 is the need for coordination between
those with technological expertise and those with knowledge of disability access issues. The
rapid pace of technology innovation can further complicate the issue. Increased inter- and intra-agency coordination among relevant personnel -- including information technology personnel,
procurement officials, telecommunications staff, equal employment opportunity professionals,
and end users with disabilities -- along with the private sector, would benefit everyone.
For increased coordination and cooperation to be efficient and effective, the Department
recommends the following:
Increased Coordination
1. The President should issue a Technology Accessibility Coordination Directive to:
a. Revitalize the Interagency Disability Coordinating Council (IDCC), as set forth in
29 U.S.C. § 794c, with the Attorney General as Chair, consistent with Executive
Order 12250, 29 U.S.C. § 2000d-1;(3)
b. Direct certain Federal agencies (including the General Services Administration,
the Department of Defense, and the Department of Transportation), and invite
other agencies (including the Federal Communications Commission and the U.S.
Postal Service) to participate as nonstatutory members in the IDCC; and
c. Direct the Department of Justice, in consultation with the Office of Personnel
Management, the EEOC, and the Access Board, to issue guidance to agencies
clarifying the relationship among sections 501, 504, and 508 of the Rehabilitation
Act.
2. The Universal Access Working Group (UAWG).(4) Each cabinet level, large, and mid-sized agency, along with representatives from small and very small agencies, should join
the inter-agency UAWG. See General Appendix A (Categories of Agencies). The
UAWG has been an instrumental force in advocating for accessible technology
throughout the Federal Government and private sector. Its relevance would be increased
if its members were designated as their agencies' representatives, rather than participating
as individual volunteers, and if more agencies were involved.
3. 508 Coordinators. Each agency should designate Coordinators for purposes of
complying with the substantive and reporting requirements of section 508. Agencies
should either select multiple Coordinators -- to represent each of the agency's
information technology, telecommunications, disability accommodations, and other
relevant sectors -- or a single representative to act as an intermediary among these
sectors. The Section 508 Coordinators of cabinet level, large, and mid-sized agencies,
along with representatives from small and very small agencies, should attend UAWG
meetings as representatives of their agencies. See General Appendix A (Categories of
Agencies). A list of all Section 508 Coordinators should be developed and distributed
among all agencies. The Section 508 Coordinators should meet regularly with agencies'
Section 504 Coordinators.
Technical Assistance
1. The General Services Administration (GSA) and the Access Board, which have statutory
authority for providing technical assistance under section 508, should share in the
following responsibilities:
a. Information Hotline. An information hotline should be established for federal
agencies, persons with disabilities, and the IT industry. The Department of
Justice's Americans with Disabilities Act Information Line should serve as a
model.
b. Technical Support Center. An interagency technical assistance support center
should be established where agencies can receive specific, hands-on assistance
tailored to their individual concerns. The Job Accommodation Network of the
President's Committee on Employment of Persons with Disabilities at the
Department of Labor should serve as a model.
c. Internet Resources. An Internet message board and listserv (an e-mail mailing list
for discussion among a group of users) should be maintained where
knowledgeable agencies can post solutions to particular problems and where
agencies trying to address EIT accessibility issues can post questions. Agencies
that have developed evaluation criteria, techniques, and reports of existing EIT
products should make these available to other agencies using these Internet
resources [recommendation of the Social Security Administration].
2. GSA should do the following:
a. Accessible Products Clearinghouse. GSA should be directed to act as a
clearinghouse for information regarding accessible EIT products. Any
manufacturer's information regarding accessibility of EIT products should be
made available to all federal contract officers and their technical representatives
through this Clearinghouse. The Energy Star and Y2K programs may provide
models on which to build.
b. Training Clearinghouse. A clearinghouse for accessible training resources -- and
training regarding accessibility -- for management, IT and procurement
personnel, and end users with disabilities should be established. Vendor
information regarding accessible training opportunities should be made available
to all agencies through this Clearinghouse.
3. Mechanism for Reliable Information. The Federal Government, in partnership with the
private sector, should explore the best mechanism to provide reliable information
(including information regarding the comparative usability of EIT products for people
with different types of disabilities) to manufacturers, vendors, and procurement officials.
Other General Implementation Recommendations
1. Alternative Dispute Resolution. Each agency should establish voluntary alternative
dispute resolution mechanisms and make them available to members of the public and
employees with disabilities as a means to resolve allegations that an agency is violating
section 508.
2. Other Government Certification Programs. Government programs which test and certify
software for federal use (such as the JFMIP certification of financial management
applications) should incorporate section 508's accessibility requirements into their
certification processes [recommendation of the Equal Employment Opportunity
Commission].
3. Voluntary Advisory Committees of Persons with Disabilities. Each cabinet level, large,
and mid-sized agency that has not already done so should form an intra-agency voluntary
advisory committee of persons with disabilities. See General Appendix A (Categories of
Agencies). Small and very small agencies are encouraged to form joint inter-agency
committees. These committees can assist agencies in recognizing accessibility issues,
finding cost-effective solutions, and accomplishing testing. Participation by people with
disabilities in all such committees should be fully voluntary. The Equal Employment
Opportunity Commission and the Office of Personnel Management should
collaboratively publish guidance to assist agencies with setting up these committees.
4. Community Partnerships. Each agency is encouraged to form partnerships with disability
rights groups. These partnerships can assist agencies with recognizing accessibility
issues, finding solutions, and accomplishing testing.
Procurement Findings and Recommendations
Section 508's enforcement provisions apply only to EIT products "procured" on or after
August 7, 2000. The Access Board's Standards to implement section 508 will be incorporated
into the Federal Acquisition Regulation (FAR). Most agencies are subject to the FAR. Some
others follow it voluntarily. The few remaining agencies, including the U.S. Postal Service, will
be required to modify their procurement regulations to incorporate the 508 Standards.
Relatively few agencies currently incorporate accessibility provisions into their EIT
procurement contracts (several of the better contract provisions have been incorporated into this
Report to serve as models for other agencies; see, e.g., The Department of Education's contract
language, attached as Procurement Appendix B). Even fewer agencies test EIT products for
accessibility prior to bid acceptance. A great majority of agencies continue to address EIT
accessibility issues on an ad hoc basis.
The Department recommends agencies take the following steps to improve their
procurement policies and practices:
1. Specific Language for RFPs and Contracts. Each agency should incorporate appropriate
procurement language that specifically addresses accessibility for persons with
disabilities in all EIT RFP's (requests for proposals) and contracts to be in compliance
with the Federal Acquisition Regulation or other applicable federal procurement
regulation.
2. Agencies Not Subject to the Federal Acquisition Regulation (FAR). Although most
agencies are covered by the FAR, any that is not should consult with the Access Board
without delay to ensure that its procurement regulations are appropriately modified to
incorporate the Section 508 Standards when they are final.
3. Discontinue Ad Hoc Approach. Each agency that has not already done so should develop
systematic ways to ensure that it is procuring accessible EIT products, rather than relying
on an ad hoc approach. This method will increase the interoperability of different types
of technology and is especially necessary as technology increases in complexity. Each
agency should review all of its procurement practices and policies, formal and informal,
to determine whether accessibility issues are appropriately addressed.
Technology-Specific Findings and Recommendations
Federal Agencies' Web Pages
Federal agencies' Internet and intranet sites contain some barriers to access for people
with disabilities. The most commonly encountered barrier is the failure to provide appropriate
and meaningful text information for visual images ("alt text" for simple images and icons and
long descriptions for more complicated graphics). This barrier, like others that are encountered
less frequently, can be eliminated quite easily with minimal design changes.
Part of the reason that agency Web pages are relatively easy for people with disabilities to
use is that most agencies have consciously decided to make their pages readily usable by people
who use older, less expensive, and less sophisticated technology. Federal Internet pages tend to
be free from the "bells and whistles" that require more particular attention to accessibility issues,
such as multimedia content or interactive features.
As agencies put more of their programs and services online, they must remain vigilant to
ensure they are not inadvertently creating barriers for people with disabilities. Online forms and
documents rendered exclusively in Adobe's portable document format (pdf) or Microsoft's
PowerPoint format may raise particular concerns.
As most barriers on agency Web sites result from an inattention to detail rather than an
underlying difficulty with the design or technology, agencies should invite people with
disabilities to inform them when they encounter barriers.
To address these issues and others detailed in the Report, the Department recommends
the following:
1. Testing Web Pages Before Posting. Each agency should evaluate for accessibility all of
its new Web pages before they are posted. Existing Web pages should be tested as they
are updated. Testing should be done with text-only browsers and, where possible, with
assistive technology such as screen reading software to ensure that the experience of users
with disabilities is comparable to that of others.
2. Agency Web Guidelines. Each agency that has developed style guidelines to maintain a
consistent "look and feel" of its Web pages should review those guidelines to ensure that
they will maximize the accessibility of the agency's Web pages.
3. The Government Printing Office (GPO). Many smaller agencies rely on the GPO for
their Web site design and maintenance. While section 508 does not apply to the GPO,
the GPO should provide leadership to ensure that all Web pages it develops or maintains
are accessible.
4. Dedicated E-mail Addresses. Because most accessibility problems on agency Web sites
result from oversight or lack of awareness of accessibility issues, rather than technical or
design difficulty, each agency should prominently post to its Internet pages an e-mail
address through which users with disabilities can inform the agency of any accessibility
barriers encountered. Each agency should be responsive to any e-mails it receives
regarding the accessibility of its Web site to people with disabilities.
5. Accessibility Information Logo. The National Endowment for the Arts, along with the
Universal Access Working Group, GSA, and the Access Board, should develop an easy-to-recognize accessibility information logo (and alternative text label). Each agency
should use this logo (and text label) to link people with disabilities who use its Web
pages with appropriate accessibility instructions and information, including an e-mail
address to the agency's accessibility point-of-contact.
6. Location of Accessibility Information. Where it makes sense to do so, such as when
placing a link to a text-only alternate Web site or when posting the accessibility
instruction logo and label, each agency should place accessibility information in the
uppermost left-hand corner of its Web pages. This location will facilitate use of the
agency's Web pages by people who use screen readers, as it is the first location from
which a screen reader will read.
7. Document Formats. As agencies put more of their programs and services online, each
must remain vigilant to ensure it is not inadvertently creating barriers for people with
disabilities. Online forms created using any of the various Web technologies pose
significant accessibility challenges to Web designers. Documents rendered exclusively in
Adobe's portable document format (pdf) or Microsoft's PowerPoint formats may raise
particular concerns. If any posted documents or forms are less than fully accessible, each
agency should also post ASCII or accessible HTML versions of the same documents,
where possible. Where exclusive reliance on an inaccessible format is unavoidable, each
agency should provide contact information where users with disabilities can request the
underlying information in an accessible format, where doing so would not impose an
undue burden on the agency or result in an fundamental alteration.
Software
Almost all software applications contained some barriers to some people with disabilities.
Most applications, however, provided a fair degree of accessibility to most people with
disabilities. Among the communities most likely to face significant barriers are those who are
blind, those with low vision, and those with multiple disabilities.
A sizable majority of the software applications used most frequently by agencies are
commercial off-the-shelf (COTS) applications used without agency modification. The most
commonly encountered barriers in COTS software fall into the categories of (1) documentation
and support;(5) and (2) programming.(6)
The Department recommends the following:
1. Training Needs Surveys. Each agency should develop and distribute "training needs"
surveys to all employees. These surveys should explicitly address training needs for
people with disabilities, especially those who use assistive technology in conjunction
with mainstream software applications. EEOC should provide guidance to agencies on
this issue.
2. Appropriate, Periodic Training. Each agency should train all IT personnel, procurement
officials, "help desks" and other support personnel, and users with disabilities, regarding
basic accessibility issues. To conserve resources, GSA and the Access Board, in
consultation with other key agencies and inter-agency groups, should create training
modules that can be shared among agencies. GSA and the Access Board should also
make available lists of appropriate training vendors. Each agency should ensure that
specialized training is available for users with disabilities for all software packages for
which training is generally provided, including training provided by third-parties on
behalf of agencies.
3. Software Compatibility Testing Centers. As agencies update and centralize their IT
architecture, they should create software compatibility testing centers at which software
can be evaluated for compatibility with existing agency platforms and with commonly
used assistive technologies. Larger agencies may wish to establish their own
compatibility testing centers. An interagency software compatibility testing center should
be established to assist smaller agencies, larger agencies without testing centers, and
private software manufacturers and developers. Centers at Department of Defense,
Department of Education, the Social Security Administration, Department of Veterans'
Affairs, and GSA can serve as models.
4. Documentation (Instructions, Help Files, User Manuals, Etc.). Many software
applications have accessibility features of which most users, trainers, 'help desk'
personnel, and others are unaware. Other software applications (such as word processors,
Adobe Acrobat, etc.) can be used to create information products. Knowledgeable users
can use these applications to create information products that are relatively accessible.
Other people may inadvertently use the same applications in such a way that the
information products they create are largely inaccessible. Each agency should require its
software vendors to include clear documentation of the accessibility features and
appropriate uses of their products to maximize accessibility.
5. "COTS Software Accessibility Manuals". Because many of the Federal Government's
current software applications may continue to be used for a long time, federal agencies
must make the most of the accessibility features built into currently-used software, rather
than rely exclusively on procurement of new accessible software. GSA and the Access
Board, in consultation with other key agencies and inter-agency groups, should consult
with software manufacturers and should develop and distribute supplemental manuals for
users of commercial off-the-shelf (COTS) software applications. These manuals should
include clear instructions for maximizing the accessibility of COTS applications currently
used by federal agencies and for promoting accessibility and minimizing barriers in the
information products some COTS applications (such as Adobe Acrobat) are used to
produce. Specific information, such as macros developed to provide shortcut keys where
none previously existed, should be incorporated into these manuals.
6. Government-Wide, Low-Cost Programming Solutions. GSA and the Access Board, in
consultation with other key agencies and inter-agency groups, should contact
manufacturers of COTS software to determine whether software updates, containing
programming "fixes" of barriers identified in this Report, may be obtained freely or
purchased for a low fee and distributed throughout all federal agencies. Each agency that
has already developed programming solutions to remove barriers to COTS applications
should be encouraged to continue this work and to share their results with all appropriate
agencies.
Telecommunications
Telecommunications poses specific accessibility issues for almost every community of
persons with disabilities, including people who are deaf or hard of hearing and those with speech
impairments, people who have difficulty pressing touch-tone buttons, persons with visual
impairments who cannot see visually displayed information such as message waiting or caller ID
indicators, and persons with cognitive impairments or learning disabilities who have difficulty
understanding or remembering serial connection choices (press 1 for ___; press 2 for ___; etc.).
Few agencies are fully utilizing the efficient, low-cost services that are available to them,
such as the Federal Information Relay Service (FIRS)(which allows deaf and hard of hearing
people to communicate via telephone with people who do not have special equipment, such as
TTYs).(7) The lack of awareness of such resources has a negative impact on federal employees
and job applicants with disabilities, as well as members of the public with disabilities. Training
is often all that is required to improve this situation.
Few agencies provide equivalent direct-access TTY connections for serial connection
services, automated call sequencing connection services, or other interactive telephone services.
As these services can be difficult or impossible to navigate using the Telephone Relay Service,
few agencies have automated telephone systems that can be used at all by people who are deaf or
hard of hearing. For minimal cost, additional lines with text messaging modes can be installed.
These serial connection services and automated interactive telephone services can be made
generally accessible to a wide variety of people with disabilities -- including people with
cognitive impairments and learning disabilities, mobility impairments affecting dexterity or
speed, and others -- simply by providing an operator.
Most agencies that provide employees with pagers have text pagers with vibration
signals; these pagers are accessible to people who are deaf or hard of hearing.
Few agencies have begun using the wide variety of disability-friendly
telecommunications products that are now offered by mainstream telecommunications
companies.
In light of these findings and others discussed in the Report, the Department recommends
the following:
1. Training. Each agency should train all federal employees who communicate by telephone
with the public or with other employees on how to use TTY's, the Telephone Relay
Service (TRS), and the Federal Information Relay Service (FIRS). GSA and the Access
Board, in consultation with the FCC, should develop a short, electronic training module
that can be made available through agency intranet sites at minimal expense.
2. TTY's in Public Areas. Each agency should provide TTY's, outlets, and shelves
wherever the agency provides telephones for members of the public.
3. TTY's in Call Centers. Each agency should install TTY lines wherever it receives a large
volume of incoming calls.
4. FIRS. GSA, in consultation with the FCC and other key agencies and inter-agency
groups, should explore upgrading the Federal Information Relay Service (FIRS) to
include video relay interpreting and speech-to-speech relay services.
5. Operators. Each cabinet level, large, and mid-sized agency should make operators
available on its interactive automated telephone services and should allow callers to
connect with operators by pressing "0" or by staying on the line. See General Appendix
A (Categories of Agencies). Small and very small agencies should explore cost-sharing
measures to provide operators for their interactive telephone services.
6. Equivalent Interactive TTY Telephone Services. Each agency should configure its
interactive telephone systems to be compatible with TTY's or should provide
equivalent TTY interactive systems containing the same functions and information (and
updated as often). This goal can be easily accomplished by adding a second telephone
line with a TTY message and TTY compatible features that are equivalent to those
provided on the interactive voice systems.
7. Equivalent TTY Toll-Free Information Services. Each agency that provides toll-free
information lines should ensure that those lines support TTY use or the agency should
maintain equivalent separate toll-free TTY information systems that are staffed to be as
responsive as the standard toll-free information lines.
8. Computer-Based TTY Equivalency Systems. GSA and the Access Board, in consultation
with the FCC and other key agencies and inter-agency groups, should explore purchasing
a government-wide license (or multiple licenses to offer to agencies) of ASCII/computer-based TTY systems to ensure that all agencies' employees with networked computers
have TTY equivalency on their network with minimal per-employee costs. Appropriate
attention should be paid to factors such as computer network security.
9. Voice Recognition Technology. GSA and the Access Board, in consultation with the
FCC and other key agencies and inter-agency groups, should explore buying multiple
licenses for voice recognition technology to install on all agencies' interactive telephone
systems.
10. 'Telecommunications Technology Assistance Center'. The FCC, in consultation with
GSA, the Access Board, and other key agencies and inter-agency groups, should establish
a telecommunications technical assistance center. This Technical Assistance Center
should assist agencies in working with manufacturers for example, to reconfigure
telephone systems to send a "wait" signal to TTY users and to take full advantage of
advances in technology that are coming from section 255 of the Telecom Act and section
508 of the Rehabilitation Act.
Kiosks and Other Information Transaction Machines
Few agencies currently use information kiosks, point-of-sale card reading machines,
electronic building directories, or other types of 'information transaction machines' or ITMs.
Where they are used, some ITMs can be made more accessible to people with mobility
impairments, such as those who use wheelchairs, simply by moving them to more accessible
locations. Other barriers, such as an ITM's failure to provide an audio mode that can be used by
people who are blind or who have low vision, can be more properly addressed by manufacturers.
Because section 508 does not require agencies to retroactively remove barriers (although
agencies continue to have nondiscrimination and reasonable accommodation obligations under
sections 501 and 504 of the Rehabilitation Act), agencies with inaccessible ITMs should ensure
that the programs or services for which nondisabled people use ITMs are accessible to people
with disabilities through alternate means.
In light of these findings and others identified in the Report, the Department recommends
the following:
1. Non-Agency-Owned ITMs. Each agency that has facilities or property containing ITMs
that are owned or controlled by other entities (including private entities, other federal
agencies, or others) should notify them of any barriers to access in their ITMs and
recommend that such entities address accessibility issues on a specific time schedule.
2. Location of ITMs. Each agency that has ITMs should ensure that its ITMs are located on
accessible routes and are otherwise accessible to people with disabilities such as those
who use wheelchairs.
3. Inaccessible ITMs. If an agency's existing ITM is inaccessible or contains inaccessible
features, the agency should ensure that whatever information or services the agency
provides on the ITM are also available through an accessible and comparably convenient
and useful alternate means of access (e.g., automated telephone service or through the
Internet). The agency should provide appropriate signage with full instructions regarding
use of the accessible alternative method of obtaining information or services.
4. Upgrading Existing ITMs. While section 508 does not generally require retrofitting
existing EIT, each agency that replaces or updates an ITM's software or hardware should
look for and take advantage of easy opportunities to improve the ITM's accessibility.
5. Instructions. Many times, an ITM contains accessible features, such as a volume control
mechanism, but instructions on how to use these features are missing or inadequate. Each
agency that has an ITM should survey the ITM and, if appropriate, contact the ITM
vendor for a full list of accessible features. The agency should provide clear instructions
in accessible formats.
Fax Machines, Copiers, Printers, and Other IT Office Equipment
Most fax machines, copiers, printers, and other IT office equipment contain barriers to
access by people with disabilities. For instance, most copiers give error messages on liquid
crystal display (LCD) screens that are generally inaccessible to people who are blind or who have
low vision. Many LCD screens are angled so that they are difficult or impossible for people who
use wheelchairs to read them.
Agencies generally found that when they used IT office equipment that was attached to
their computer network, many of these barriers were eliminated. Most networked office
equipment is designed to communicate with the user while he or she is at his or her workstation.
Desktop computers can be easily equipped with assistive technology, such as screen readers, for
people with disabilities.
For these reasons, and others set forth in the Report, the Department recommends the
following:
1. Instructions. Many times, office machines contain accessible features, such as a volume
control mechanism on a fax machine, but instructions on how to use these features are
missing or inadequate. Each agency should survey its fax machines, copiers, and printers
and, if appropriate, contact vendors for a full list of accessible features. The agency
should provide clear instructions in accessible formats.
2. Networked IT Office Equipment. The extent to which copiers and fax machines are
accessible is greatly enhanced when the user can send commands from an attached
desktop computer terminal (such terminals may be easily outfitted with the appropriate
assistive technology to meet an individual's needs). Each agency should, in appropriate
circumstances, seek out network solutions over stand-alone machines when such
solutions would provide a greater degree of accessibility for employees and members of
the public with disabilities.
3. Instructions for Alternatives. For inaccessible IT office equipment that is available to the
general public or a large number of employees, each agency should ensure that accessible
instructions are available on how a person with a disability can obtain accessible
alternative services (such as where to seek assistance).
1. This document is available on the Department of Justice's section 508 Web site
(www.usdoj.gov/crt/508). People with disabilities may request copies in Braille, large print, or
on computer disk by calling 1-800-514-0301 (voice) or 1-800-514-0383 (TTY).
2. Some people who are blind and people who are deaf-blind use computer devices called
"refreshable Braille displays," which move pins up and down to form Braille letters. The user
"reads" the Braille letters across a line, then advances the Braille display to the next line when
ready.
3. Revitalization of the IDCC will enable it to function as a central coordination point to
eliminate duplication of efforts and/or inconsistencies among agencies and inter-agency groups.
4. The Universal Access Working Group is part of the Federal Information Services
Applications Council of the National Science and Technology Council's Committee on
Computing, Information, and Communications. It is coordinated through the Center for IT
Accommodation in the Office of Governmentwide Policy at the General Services
Administration.
5. Frequently encountered documentation and support barriers include:
- A lack of clear instructions for keyboard functions (26%)
- Instructions for keyboard use not widely available (30%)
- Manuals and documentation are not provided in an electronic format with text
descriptions of charts, graphs, etc. (37%)
- Specialized training is not provided for users with disabilities (53%)
6. Frequently encountered programming barriers include:
- Lack of shortcut keys (37%)
- Poorly located field labels and descriptions (24%)
- Application won't allow users to override default fonts for printing and text
displays (28%)
- Application does not support "print to ASCII" (26%)
7. TTYs are text telephones. They are also called 'TDDs' or 'telecommunications devices
for deaf persons.'
