Ask the Experts: Web Accessibility


Larry Gillick: I'm Larry Gillick, and this is the US Department of the Interior. We're here to talk about the new 508 compliance, or as it said on that slide, "The Revised Section 508 Standards -- Major Challenges and Issues."

I don't know about the rest of the government, but here and there we've had some interesting challenges in reading, understanding, and trying to implement some of the parts of the new guidance, so we figured we'd call the experts.

At least in these two cases, I think we've got it right. We've got Tim Creagan and Bruce Bailey from the Access Board. I don't think we could do much better for this, but you guys can contest that if you want, but I don't think you will.

Anyway, so let's do that formal introduction thing, which says Section 508 of the Rehabilitation Act of 1973 as amended charged the Access Board, an independent federal agency with the responsibility of developing accessibility standards for IT products and services to comply with the law.

Federal agencies must ensure that IT products and services developed, procured, maintained and used conform to these accessibility standards. The US Access Board published the original Section 508 Standards in 36 CFR 1194, way back in December 21, 2000, and the revised 508 Standards on January 18th, 2017.

Tim Creagan, to my immediate right, your left, is the senior accessibility specialist, and Bruce Bailey is the accessibility IT specialist at the US Access Board. Before they go on, I should tell everybody. You can't tell from where you're sitting, but it's really warm up here on the stage. If you see us start to peel down the vest, the jackets, and ties and stuff, it's nothing person. It's just it's really warm here.

With that said, Tim and Bruce.

Tim Creagan: Thank you, Larry. We look forward to entertaining many of your questions. We've had a lot of your questions presented to us beforehand, and we have drafted these initial opening slides in response to your questions. We'll hope to have a good, focused presentation today and answer a lot of your questions.

Bruce Bailey: Hi, I'm Bruce. I'll be leading us off, if we could go to the first...You're way ahead of me here. This is not going to work for me, if I can't see the slide. Slide number two, we really only have four bullets here. We're going to talk about the purpose and overview of 508, because we wanted to set some framing. Oh, look at that. They magically made a screen appear for me in the room. That is awesome.

We're going to talk about key changes with the revised standards. We've been calling it, for a couple or three years now, we were talking about the 508 Refresh. We got everybody who uses it comfortable and used to that language, so that's how we still characterize it on our website.

As we've been doing our more formal presentations, we're now talking about the revised 508 Standards, as compared to the original 508 Standards.

We will maybe be mentioning something about the rule formation and the organization, because that's quite a big difference. We're going to be talking about the WCAG 2.0, incorporation by reference. We're going to try and get through all of those four points in about 15 or 20 minutes.

We had already had our presentation done. Then we got the instructions to only talk for 10 minutes, and then all Q&A for the 90 minutes. I'm bad at following instructions, so what we did is we took all of your excellent questions, and we've worked them into our presentation.

We're going to be interrupting to do questions throughout the whole thing and we'll take questions as they come in over the Internet and in the room. Please, we won't be pausing, per se till we get to the very end, but, in the room, wave me at me or Larry and hopefully we have some good...

Oh, you can't see the stuff that's coming in online, can you? If we get something good coming in online, people in the back of the room are going to have figure out how to interrupt us in the least disruptive way possible.

Larry: You can't see him, because he's not up here on the stage, but there's a guy in the back of the room, Nate. Doesn't help if he raises his hand, but we can see him if he waves his hand, and he can see all the questions come in.

Bruce: I'm going to pay attention to whatever Larry tells me to do, and that should keep me straight.

Slide three, the Rehab Over Act, this is just paraphrasing exactly what you just said, Larry. "The Rehabilitation Act prohibits discrimination on the basis of disability in programs conducted by federal agencies, programs receiving federal funding assistance, in federal employment, and in the employment practices of federal contractors." That's right off of

It's in the context of the Rehabilitation Act, which I always like to remind folks is in the context of civil rights. Very often, when we're talking about civil rights, we're not always going to be the most open-ended and considerate of the difficulties, because it's a civil right. It's very important to a foundational way of how we do things and do business as the federal government.

Let's go over to the next slide, four. Section 504 and 508 of the Rehabilitation Act get a lot of particular mention. If you've got kids in school, they'll talk about 504 programs, and they're talking about 504 of the Rehabilitation Act.

504, generally, we're not talking about that today. It requires reasonable accommodations, and they're tailored to an individual. They're very specific to that individual. They're one-on-one solutions. They're developed as they're needed.

One of the things that's very common with that is to have technology as part of that solution. You might have something called assistive technology, which is like your screen reading software, your screen magnification software, as part of that solution that's part of that 504 accommodation.

Reasonable accommodations and 504 is not limited to information communications technology at all. Whereas Section 508 of the Rehabilitation Act is very specific to computers and other electronic technology, information communications technology. It's proactive. It requires the ICT to be accessible from the very beginning as you buy it, as you put it online.

It's affirmative action kind of thing. You don't do it because you have a need for it. You do it because it's part of the requirement. It's part of our doing business. 504 is only about computers and technology. It's not about other kinds of accommodation that might be covered by 504.

Next slide, five.

Larry mentioned that, just some highlighted bullets that he mentioned, that in December of 2000, we had the original 508 standards. I like to backdate that a little bit further on this slide with December 26 of 1973, the Rehabilitation Act of 1973. This is an old piece of statute. '73 puts it in the context of all the other civil rights actions going on at the time.

It had a section 508 back then, section 504, section 508 of the Rehab Act back in '73. In 1973, it had no details as to what it meant for computers to be conducted by, purchased by the federal government to be accessible. It was just kind of aspirational direction.

In 1998, Congress with the Rehabilitation Act of 1998, the Access Board was charged with developing actual, concrete standards. 2000, Larry mentioned, we had issued out the months. Then six months later, June 21, 2001, implementation was due.

That was really a pretty tough call back in the day that you had to go from zero, basically, to 60 miles an hour with six months warning. Then in this year, in January 18th, we issued our revised 50CC standards. We'd been working on those for six, what, seven, eight years, Tim? A long time.

Tim: 11.

Bruce: 11, oh gosh. That's when I first came to the Access Board. I was working with the US Department of Education before that. Those are implementation date a year later of January 18th, 2018. We're going form 60 miles an hour to 70, 80 miles an hour in my little analogy. You've got a whole year to make up that difference. There is the safe harbor clause, which will be coming back on in a minute.

Let's go to slide five or next slide. I don't know what my numbers are.

There was something else Larry mentioned in his introduction, the difference between the statute and the standards. The standards were the part that the Access Board was charged with developing those with input from many other agencies. The agencies are the ones that enforce it and are really responsible for making it work.

We, the Access Board, don't have any kind of oversight, or policing, or anything else really. We're just in charge of developing the standards and providing technical assistance on those standards. Anything you can say to me can't get you in trouble because I'm not the 508 police. We just don't have that kind of powers at all.

Next slide.

I do want to restate that general charts show you...We'll do this periodically throughout the presentation, we have the actual excerpt from the standards. This is my first example of that, 203.1, Access to Functionality. There'll always be a chapter and a section numbers so that formatting stands out, in this presentation at least.

E203.1 General, "Agency shall ensure," there's some blah, blah, blah. "That federal employees with disabilities have access to and use of information and data that is comparable to the access and use by federal employees who are not individuals with disabilities." Again, the general, proactive, civil rights charging language.

Paragraph V is similar to that. "That members of the public with disabilities who are seeking information or data from a federal agency have access to and use of information and data that is comparable to that provided by members of the public who are not individual with disability."

Again, these are this E203.1 language is coming right out of the statute, but it's in the 508 standards, just the general, broad requirements.

That gets us to our very first question, slide eight. 95 percent of what I do are training videos for a specific audience. Not once has there ever been a request for an audio description of how to fill out forms and paperwork.

The answer there is what that I don't care? The answer is the Rehabilitation Act is civil rights statute. Being responsive to our obligation under Section 508 is something that distinguishes us from the private sector.

Take the long view of who might be using the training you develop. You're a federal employee. You're developing training videos on doing forms and paperwork, which seems, I don't know. Does that seem mundane? It's not mundane. It's part of the work we do every day.

You're providing support to your federal employee on forms and paperwork. It's important work. It's important that that work be accessible no matter who gets hired. This is why I include some of the perspective there.

If Section 504, which is the accommodation of the Rehab Act, if that had been working perfectly, maybe there never would have been a need to have these 508 standards, but it didn't work in the federal employment.

The federal government was not a model of employer disabilities. It's all about making sure that we are not building barriers to what we do. We're not building barriers with our communications technology, at least.

That everything we do is accessible to anyone we might hire now and in the future. I'm starting to get choked up on that. I didn't think I would. It's about very important basis for where 508 comes from. With that, I'll turn this over to Tim.

Tim: Thank you, Bruce. We'll give you a moment to recover.

Bruce: I need it.

Tim: Thank you. We're on slide nine. What we're going to do is we're going to shift gears a little bit. We're going to talk about changes between the revised 508 standards and the original 508 standards.

I'm sure that all of you in the room -- and I'll look for nods and acknowledgment -- are familiar with the original 508 standards, those that were promulgated are 2000. You remember the nomenclature, like 1194.21, 22, etc.

Bruce: I don't.

Tim: Let's talk about the new revised standards, and how they're different. First of all, the formatting for the rules is very different. Secondly, the new rules are feature oriented instead of product oriented. The old rule is you were worried about what something was called.

Is it a telephone? Is it a computer? Is it software? There was no concept of software as a service, multi-function copy machines, smartphones. If you think about it, you try to analyze a device that has multiple functions.

You say, is it mostly a phone, or is it mostly a computer, or is it mostly something else? What we found during the years of revising the standards was we saw that technology had changed. There was much more of a focus across a variety of platforms on what stuff did.

You see when you look at the new standards, those of you who are looking at it in the context of what the old ones said, I suppose to those of us who are seeing them brand new, you're going to see that it's very much feature oriented.

Another item very important, especially for those of us in the federal sector, is delineation of covered electronic content. You've already seen from the first couple questions that Bruce handled, people are very concerned about what is covered electronic content.

As a federal employee, when I produce content, my deliverables, when do they have to be made accessible? What is the context for that? I think you'll find that in this discussion of the new rules, we've attempted, and I think we are much clearer, on what is actually covered content.

Then finally, we're going to be talking about something called the application of WCAG 2.0, which is the Web Content Accessibility Guideline. One of the requirements in federal rule-making is that when you seek to reference a standard, the preference is that you reference existing or external standards.

In this case, there are standards for Web accessibility, which we found upon closer examination that they could apply not only to Web content, but also to non-Web content. We'll talk about that in the next slide.

Next slide. This is a graphic, and it's two oblongs intersecting. What it is, it's giving you a graphic depiction of the new rules. On one hand, you have the Section 508 standards, which applies to information and communications technology that is procured, used, maintained, or developed by federal agencies.

That's the large circle on the one hand, which is called Appendix A. On the extreme right, Appendix B is Section 255. Section 255 applies to telecommunications products, and it applies to telecommunications manufacturers when they develop telecommunications materials.

What you have in each of those large exterior circles are what are called the administration chapters and the scoping chapters, which are chapters one and two. In the middle, Appendix C, you have what are called the functional performance criteria, which is chapter three, and then chapters four and five, which are hardware and software, respectively.

Chapter six, which is support documentation, and chapter seven, which is a listing of all the reference standards that we've talked about. Very briefly, the old 508 standards were organized by product types. The new 508 standards are organized into seven chapters.

The first two chapters are application and scoping, and then chapter three was functional performance criteria. Chapters four and five with technical requirements, chapter six with the requirements for support documentation. That is when your ICT ships, and there's instructions on how to use it, that's an example of the support documentation. It's required to be in accessible formats.

Finally, chapter seven is a listing of all the specific technical requirements that are referenced throughout the document.

Larry: Tim, if you don't mind, I'm going to interrupt for one second and just say, this is fine. I don't often dive into...That's not what caught my ear. What caught my ear was that you were on the fly doing audio description of a graphic.

Tim: Yes.

Larry: I'm assuming that on purpose.

Tim: That was. You've discovered my clever plan. I am illustrating the practice of audio description, because...

Larry: We didn't plan this. We didn't have this conversation before. I'm actually interrupting him. This is not a shtick.

Tim: We only practiced it five times. No, but seriously, this is an example of audio description. Here, you have a group of panelists. You would describe them for people.

If it was necessary to understand what we looked like for the purposes of the comprehension of content, you would say, "The incredibly handsome gentlemen on either side, and the troll in the middle," if that were important to the meaning.

What I'm doing is I'm also explaining what it is that I'm talking about. I give it a description term, and I'm explaining that it's a graphic. It's two intersecting oblongs. The purpose of the illustration is to depict the fact that there are two freestanding laws which interact or intersect because they have technical criteria in common.

For those of you who are familiar with other work done by the Access Board, this is exactly the model we used when we revised and drafted the standards and guidelines for the Americans with Disabilities Act and the Architectural Barriers Act.

The scoping chapters and definitions chapters are chapters one and two, and each of those two laws. Then the shared technical requirements overlap, because they're the same.

Bruce: I'm glad you interrupted us with that, Larry, because Tim and I will do that without thinking about it because we're fairly practiced with it. It is something that I think is unusual for people to think of. It's really just assuming that you're on the phone, what would you say? It's not even that hard once you get used to it.

I cringe every time, especially if I'm going to a 508 or a 504 or some other accessibility related conferences, the speaker's some outside person who's brilliant and genius but not used to talking with somebody who might be blind in the audience or something. They'll say all the time, "As you can see on the slide..." No, not as I can see on the slide! Tell me what is it that you think's important.

It's helpful also because a lot of times people put off these infographics. They're just overwhelming to two-thirds of the people in the audience where I'm familiar with the subject. They don't know where to focus. Thank you.

Larry: No problem. I cheated. Before I had the job at Interior, I had this side job with another science group. I used to take science presentations and turn them into human speech. It was a thing.

Anyway, past job. Time to move on slides-wise. [laughs] Slide 11.

Tim: That's our regularly scheduled broadcast. Now, we're moving on to the next slide.

I'm going into some detail about the fact that the revised standards are feature-oriented instead of product-oriented. In the original section 508 standards, there were six sections based on product type.

First, of course software applications and operating systems, web-based intranet and Internet information and applications, telecommunications product, video and multimedia product, self-contained closed product -- who could forget those? -- and desktop and portable computers.

In the revised standards, you basically have two chapters that are based on features. You have chapter four which is hardware and chapter five which is software. If you think about it, all those six product chapters can fit neatly into one of these two chapters.

This isn't for today's presentation. When you get a chance, when you're reading the new rules at night because you have them by your bedside, you can look through and you can find the provisions that map up to each one of these product categories that we've talked about. These are just highlights for you. Next slide, please.

Bruce: Wait, before you go on...

Tim: Go ahead.

Bruce: Go back to slide 11 in there if you would. With those six product categories, it's really interesting for us because of course the idea was that you could, at least back in the day, you'd have these six distinct things, and a phone now, a smart phone, does all six of those categories. The rules have been a little bit broken for a while. Thank you.

Tim: That reminds me. I'm making a little digression. In addition to today's presentation, I just want to remind you all that the Access Board in conjunction with other agencies has developed a ton of technical assistance. Specifically, we have a webinar series every other month on, this year's topic is, the new 508 standards.

One of the things that's very interesting area is back in July, we did a webinar on hardware where we talked about hardware features of telecommunications products for example. Then just three weeks ago, at the end of September, we did another webinar on software where we talked about software features, and we used again telecommunications product as an example of how to apply the provisions.

For those of you who are interested, you can find the webinar links on our Access Board home page which is There's a link that says webinars which will take you to that. We'll be throwing in little plugs for all of this throughout.

I just wanted to remind you that all of what we're looking at is part of our continuum. There's a lot of other agencies that are working on these and developing technical materials. We're always glad to talk about it. We're always glad to come and tell you about the materials and opportunities we have available.

Having said that, let's move on to one of our most important considerations as federal employees. What is covered electronic content? This slide breaks it down for us and says there's two provisions in the revised standards which are very important, E 205.2 public facing and E 205.3 which is agency official communications.

First of all, E means that it is a 508 provision, and the fact that it's in the 200 series mean that it's in the chapter two of the 508 standards. This is the scoping for 508. You know that just from seeing the E prefix and the 200 series.

Public facing is that electronic content that is public facing. That means everything you're familiar with on public facing websites. That's all your social media. That's everything that members of the general public would see, have access to.

Conversely, E 205.3 is agency official communication. What is that? That is electronic content that is not public facing, does not conform to the 508 standards. When such content constitutes official business, and is communicated by an agency through one or more of the following. Next slide, please.

There's nine categories here of E 205.3, of agency official communications, categories A-I. I'll just go through them very quickly. A is an emergency notification, B, an initial or final decision adjudicating an administrative claim or proceeding, C, an internal or external program or policy announcement, D, a notice of benefits, program eligibility, employment opportunity, or personal action, E, a formal acknowledgment of receipt, F, a survey questionnaire.

A survey questionnaire would be those types of questionnaires that are limited in duration and time and in the audience. I know the types that you typically need to get permission I believe it's from OPM to have them, and they're limited in duration questionnaires.

It applies to a very specific type of questionnaire. It does not apply to materials produced in the course of litigation for example. Department of Justice made very clear to get that clear with us, so it's a very specific item.

G is a template or form. H is educational training materials, about which you have provided us a lot of questions, and I is intranet content designed as a Web page. These are the nine types of categories. Remember, they're not public facing, they're agency official communication, and it's only these nine categories that have to be made accessible.

There are some exceptions which we're not going to talk about today, one of which is for NOAA, our National Archives. When they receive material, they're not required to make it accessible because they're receiving it as part of their business. Next slide please.

Bruce: Wait, go back one. One I like to mention with this is, of these nine things, only the last two were clearly covered with the original 508 standards, that is the education or training materials, there was a section about multimedia productions that are agency user instructions, and then I, the intranet content designed as a Web page, original 508 applied to just that, Internet technologies. Certainly, all the internal facing websites have always been covered, so that's not new.

Why did we do this? Over the years, we got all these questions about PDF attachments mostly but all these things that were going out through email. When are those covered? Or if you've got a SharePoint site where you're sharing documents, it's just a network drive, is that covered?

I think we'll come back to that a little bit more, but mostly no, not unless it's one of these nine categories. SharePoint is an intranet site, but if it's just a file listing, the individual files are not intranet content designed as a Web page. Thank you.

Tim: Because they're not intranet content designed as a Web page, therefore they would not need to be made accessible.

Bruce: Under 508.

Tim: What we're trying to do when we're going through these logic chains, the bottom line is, yes, you have this accessible or, no, you don't.

The first question I have is, "How are we supposed to share raw footage? Being unable to share raw footage on a short turnaround would be unacceptable." Here's where you look at the covered electronic content. You say yourself raw footage is not covered because it's not public facing, E 205.2, and it's not in one of the nine categories for agency official communication, E 205.3.

Bruce: Let's pause on that. Stop me if I'm wrong, there's more than one news agency out there. There's lots of news agencies. You could put your footage on a relatively public but not very featured site so that all the agencies can get that material. Because you can't just email for example everybody giant files of video whereas you could, say, plant it out on

You could do that, and that would be super convenient, easy to do, and I imagine someone probably already does that somewhere out in the government. It's probably a fairly common practice. If we had to, say, audio describe hours and hours of footage in order to just get it out to the press, that would be hard. What's our answer on that? What's our compass?

Tim: Let's go back a slide. Let me ask you the question. Looking at the nine categories up there, where do you put raw footage?

Larry: Isn't this for internal facing stuff?

Bruce: He's right. Let's go to the next slide after this one where we've got a very closely related question. We're still not going to answer it right away.

Tim: Go back. Similar question to what you just said and what the previous slide just said, "How are we supposed to share video, B roll specific for scientific research? We have underwater cameras and drones that film thousands of hours of footage and share those publicly so that researchers can easily access that content. Audio describing underwater with drone footage would cost hundreds of thousands of dollars each year."

Then it says if you share them publicly, then it's not an agency communication because it's public facing, and we're going to come back to this question in further detail.

Bruce: Larry, this Bruce again. I heard you say if we're sharing these with other agencies, so maybe it's on Dropbox, that kind of thing...

Larry: I think like "New York Times," "Wall Street Journal," Fox News, whoever.

Bruce: That's the public. Let's work our way up to we are sharing it with the public because I'm not sure that I think...Is it public facing or not? It sounds like it is, but you only think Fox News and other newscasters are interested in it as opposed to John Q. Public who knows where to go. They can find it easily or do they need an account?

Larry: I guess that would be part of my question. If part of my answer is how do I make it work so I can keep doing my daily business, I would like an answer to that because I don't see us not sharing video with news agency. I don't see us not sharing video with bloggers. I don't see us not sharing video in general.

On the other hand, let's say we do a thing out in Yellowstone. We have hours and hours and hours of footage. All we really want to do is share it with the press agencies that will gather it up, slice it up into tiny little bits, and feed it back out to the American public because that's what they do.

I could individually email all of them. I'm not going to say that just seems hard, but it seems untenably difficult because there's a very large number of organizations that do news. Some I don't even know about, and frankly I shouldn't have to know all of them.

I shouldn't have to judge whether I'm going to give something to "The New York Times" or that blogger down the road. They're only looking for the raw footage, super simple.

Wait, if I've got to audio describe it, now not only will they not get it in time for it to be news, they might not get it at all because we might not be able to do that kind of work.

Bruce: Let's come around to that one in the end because I think we're going to get to a question paired answer that's very close to that.

Tim: [off-mic speech]

Bruce: This is me talking anyway, great. All right.

Slide, I can't read these numbers, 26, broad application of WCAG 2.0. Now, you've complimented our audio description abilities. I'm really sad I didn't put my graphic in here. There's a lot in WCAG 2.0 that goes beyond the parts that we're citing.

We've incorporated WCAG 2.0 at the double A level of compliance which means the level A success criteria, the level double A success criteria, it means the performance requirements, it means the definitions. Since we're doing double A, we're not doing the triple A success criteria. I'll give you an example of that in a little bit.

One of the things that slowed down our rule making is that we went well beyond what the authors of WCAG 2.0 did in our proposed rule in that we said, "Well, you can just use the WCAG 2.0 success criteria to evaluate everything, documents and software user interfaces. You just squint a little bit, and they work as they are because WCAG 2.0 was technology neutral. If it works on a PDF document on the web, why wouldn't it work on a PDF document that goes out by email?"

That was a little radical and subject to a lot of feedback. We went through that process. In the end, we came out where we were, that we're applying WCAG 2.0 level double A to Web content and covered non-Web documents. I have the cite number, E205.4. We're also applying it as part of software user interfaces. There's a little more, E207.2.

We're also applying it to software that's used for content creation as authoring tools. That your authoring tool needs to be able to support WCAG 2.0 when exporting. That's 504.2.

Then our fourth major citation is for support documentation. We're not going to be talking about that today, but original 508 just talks about the documentation, support, and services are accessible. We're using WCAG 2.0 as the benchmark for the documentation part of electronic support documentation as to being accessible or not.

Then the other major shift, next slide, please, is that we do have this pretty broad safe harbor provision with the revised 508 standards, E208.2. I've got the verbatim language here.

"Any component or portion of existing ICT that complies with an earlier standard issued pursuant to section 508 of the Rehabilitation Act of 1973 as amended and that has not been altered on or after January 18th, 2018 shall not be required to be modified to conform to the revised 508 standards." It's basically a pretty big old grandfathering clause.

Existing ICT and alteration hard to find in E104.4. That's our definitions section. Anything that's not altered and already exists and already conforms doesn't need to be updated for the 508. That's a pretty important out if you will or a loophole some people have characterized as for agencies that have been following 508 all along and have a lot of stuff up. That gets us to our third or fourth question that we got ahead of time. Next slide, please.

"Maybe most importantly is this a retroactive exercise? We have 572 videos on YouTube, 581 videos on Flickr. In 2016 alone, we published over 700 videos on Facebook. If we're required to retroactively alter these videos to meet the needs of the memo that likely shut down the entire public affairs program and/or we just stop publishing videos."

My first answer to that is no, this is not a retroactive exercise. There is this general exception for legacy ICT, but that only helps if 508 was addressed in the past and as the videos have not been altered. Anyway, if that's the case, there's no requirement for additional remediation.

My bullet points here are pretty important, that the accessibility requirements for multimedia are not new, that agencies have had legal obligations to provide captioning and audio description for public facing videos since June of 2001, which is why we had our timeline up at the beginning.

Let's take a look at what those requirements were from 2000 and 2001 in slide 19. 119422, this is all these numbers that Tim and I have memorized and love to roll off our tongues, and Larry says, "Nobody knows those."

Tim: He is correct.

Bruce: [laughs] It is kind of how we reference them. Is this 119422B? Like that means anything.

Anyway, it reads, "Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation." Then on 119424, we have C and D. C is, "All training and information video and multimedia productions which support the agency's mission regardless of format that contains speech or other audio information necessary for the comprehension of content shall be open or closed captions."

D is very similar. "All training and information video and multimedia productions which support the agency's mission regardless of format that contain visual information necessary for the comprehension of the content shall be audio described." Again, since December of 2000. Next slide.

This is probably the part of the WCAG 2.0 reference that people are seeing for the first time and getting a little bit concerned about. The revised 508 standards, again 2017 come to 2018, these are the excerpts from the level two double A success criteria, 1.2,2.

The WCAG success criteria will always have three-digit numbers separated by two periods. 1.2.2. captions pre-recorded, that's the title. "Captions are provided for all pre-recorded audio content and synchronized media except where the media is a media alternative for text and clearly labeled as such, level A."

Some of these terms of art if you will or vernacular are a little bit specific, so they don't talk about multimedia. They talk about synchronized media, just a little bit more precise. Then there's this concept of a media alternative for text that's not really too important because it's pretty rare.

The basic idea that if you've got pre-recorded multimedia, that it needs to be captioned. 1.2.4 is similar, for captions live. "Captions are provided for all live audio content and synchronized media." That's level double A. That one's interesting because one's level A. One's level double A. That hints at some of the structure from WCAG 2.0 where you do have these multiple levels.

The requirement for audio description, also at level double A, 1.2.5, audio description pre-recorded. "Audio description is provided for all pre-recorded video content and synchronized media, level double A."

One of the things that's kind of neat with this little example about captioning and audio description is it answers one of the questions people frequently have, why did you go with level double A instead of level A? The level double A really matched what we were already doing with the original 508.

With WCAG 2.0 at level A, you miss out on captions on live materials, you miss out on audio descriptions. That's a very high bar for accessibility really if we just stuck with level A. The example here that I've got...

Larry: If you don't mind my asking...

Bruce: Go ahead.

Larry: Right there, when I hear not a very high bar, I think, "That must mean audio description is a pretty common feature on video players," and it's not. Audio description is not a common feature on commercially available and open source video players.

I'm not saying you can't scrape and find and change your technology stack in order to accommodate this, but you need to scrape and find and change your technology stack to make this happen. Audio description has not stuck.

Let's pick out something I don't like particularly but we use it a lot, YouTube. There's no audio description button on YouTube. I don't know of a plan...Maybe they're going to do it tomorrow. I don't know, but I haven't heard of that.

The common video players that we use at our agency don't easily accommodate audio description. The common players all across the government don't readily accommodate audio description.

I don't tend to think of it as a person using these in the field as this being a particularly low bar. It's much less easy to deal with than closed captioning which we have ways of doing that within our agency. We've got systems, workflows, that make this happen. There's not a lot of established workflow around audio description.

Bruce: Low bar, you're correct. It's not a fair characterization because it's a good bit of work. It's burden. It's not an undue burden, which we'll get to in a minute, but it's a burden. It's extra work.

So many of these other technologies have gotten so much easier to do. Video streaming used to be a high bar, and now it's kind of a low bar. The work of captioning and audio description is pretty much the same as it was 20 years ago, meaning that it's a good bit of work.

Also, informing these standards is technology not just in the Web sphere but also in general. I agree with you the players, YouTube, even Microsoft Windows Media Player, have not been great at supporting audio description.

On the other hand, it is pretty old school technology that's been around. Your DVD players which nobody I guess is using anymore -- we've gotten past all that -- but captioning has been commonly available on TVs for decades at this point.

Audio description also been there, not as well supported as captioning being. That's true of your broadcast media. It's true of the DVD players. It's also true of the DVD themselves if they have it.

In terms of Windows Media Player and YouTube where I want to say it is, is can't you have one video in YouTube that's Spanish and one that's English and have the same set of video? You select the audio track that you want associated for that. That's a question for Larry. Don't forget to turn on your mike.

Larry: It's not nearly as easy to do that as it is to turn on closed captioning.

Bruce: I agree with that!

Larry: Again, I'm not trying to say that this is all impossible. I'm just saying this a bigger lift than most of the other questions that we have on the table. In any conversation with any group of people who work in video production, the one that bites us is audio description because you have to get someone who's good at it, which is hard. That's a thing.

I don't want to say it's super easy to get a transcriptionist, but I have a phone number I can call, and transcriptionists magically show up, like this event has closed captioning associated with it. We got that with a credit card purchase and a phone call.

We have a pretty darn good embedder of closed captioning complete with formattable text, fonts, because, as we all know, disabilities tend not to travel alone. They tend to travel in packs. You might have hearing issues and visual issues at the same time. Our captioning can handle that.

Wow, description, that's a whole different beast. Again, as a practitioner, I look at that when I say, "I can solve it, but it's not elegant. It's not super practical. It's not easy to do under deadline.

It's really a challenge to get it done in the amount of time that you would have to make something be news for example, to put something out for the American public in a way and in a time that it's still new."

I hope that made sense. I'm trying to meat it up.


Bruce: ...Makes perfect sense.

Larry: This is hard, man.

Bruce: For your pre-recorded stuff that's not such a time emergency, I want to say talk to your folks that have figured out how to have multiple languages without reshooting the whole video. Usually when I've seen audio description in actual practice, yes, old school TVs had an audio describe button you could turn on, and it doesn't work very well, and it's not very widely supported.

What the way people seem to be doing audio description in practice is, one, they're shooting talking heads and everybody's talking the whole time. Audio description doesn't require adding a separate track.

If your default presentation has lots of robust audio, and it doesn't have to be perfect, that can count as being audio described, and it meets the definition which we'll get to in three slides. For most government work, that covers it right there.

Then the second thing I would say is if you look at how you're doing...If you're providing, say, a Spanish track, your audio description track could just be the third track that you're putting on top of that. Now you still need the professional audio description which is an art form of itself too, but at least for pre-recorded stuff, it should be more feasible.

This also ties in or what I'm working out to is my last bullet here that I've got scratched out which one of the things that we have lost with the move to WCAG 2.0 level double A is we've lost the requirement for audio description on live events.

1.2.9, again, this is excerpted from WCAG 2.0, audio only live, an alternative for time-based media that presents equivalent information for live audio content that's provided, level triple A. The triple A stuff we haven't incorporated by reference.

Original 508 didn't make the distinguishing feature between live and pre-recorded. By going to this international standard, we have lost that one particular requirement on live events. Again, we're going to be coming back to this a little bit, but I'm ready to shift over to Tim again.

Tim: OK.


Tim: [inaudible 46:02] time. It's starting now. Good.

We have more questions on captioning and social media first. I'm going to go out on a limb and say it's be impossible for us to develop an SOT file or a description for Facebook and YouTube for 360 videos. We do offer ample descriptions of the videos generally, but video control is in the hand of the end user. There's no way for us to know what they're looking at.

Bruce: There's sort of a punctuation issue here. The writer is not saying that they have 360 videos. They're saying in a 360-degree video environment.

Tim: Oh, thank you!


Bruce: That's really hard to audio describe because you can't say I'm going to zoom in on...Let's say we're in an environment like that. I could be looking at Sid. I could be looking at that gentleman right over there or the nice young lady in front of him. You cannot know where that person is pointed using the technology that exists right now. I didn't think about this earlier, but I totally agree with this. I have no idea how to describe that.

Tim: You can't describe it yourself as oriented in a particular time and space. The speaker couldn't say, "From my perspective, I'm rotating to my right so many degree, and I'm now seeing..."

Bruce: No, you literally can't because while that's going on, the other person, the person actually doing the viewing, might be spinning to the left. You're free to look where you want. Imagine any movie representation of playing a video game in VR space. You don't know where this person is going. You don't really know where they're looking.

We don't have the technology to say we know that I'm looking at the cameraperson. Literally the video doesn't know what I'm looking at. The player certainly doesn't know what I'm looking at. I could say, "This is video of being in a car going down a highway," but it won't know whether I'm looking down into the valley or up into the sunshine behind me. Does that make sense?

Tim: No. What you're saying is this is specific type of video which allows the perspective to change.

Bruce: Full on immersive 360 degree and yet in full motion at the same time.

Tim: I guess the question would be then if you couldn't make it accessible, then you'd have to say the justification for purchasing this for the agency is what?

Bruce: I don't know what you mean by purchasing it.

Larry: I think we're going to get at this at fundamental alteration and sensory experience. Let's just proceed.

Tim: Which is what you were going to say.

Larry: I wasn't understanding purchase because most of the stuff we do, we don't buy it. We literally go out into the field, and we press record on a camera, bring it back to the shop with us and say, "Boy, the inside of the Washington Monument is awesome!" Because it is.

In fact, the gentleman in the back there, Nate, we talked about earlier, he's been up in that thing with a camera. Let's say we're going up the stairs, but are we looking to the left where the cool whatever is or am I looking over on the right where the other equally cool whatever is? We have no idea of knowing that.

Tim: What you're saying is it's a sensory experience of the inside of the Washington Monument going up the steps?

Larry: Yes.

Tim: You couldn't just say that?

Larry: That would be really short. I guess I could say that, but it doesn't feel like description.

Tim: Remember, it depends on what the content is that you're talking about. If it is a sensory experience, I guess you're going to have to describe it the best way you can.

Bruce: We get to this and sensory experiences in four slides.

Larry: All right. Let's go four slides in just a moment.

Tim: The other important part of this answer is the 508 requirements are proactive, meaning that your first requirement shouldn't be, "Ooh, I'm going to get cool stuff." It should be, "Whatever I'm putting out on behalf of my agency should be accessible to members of the general public and/or its federal employees."

It's not like you people are too much trouble, so I'm not going to bother to address your civil rights issues today by providing you access to this cool stuff. It doesn't work that way.

When I first read this question, what it sounded like you had a whole bunch of videos that were not captioned or whatever, that had been posted. In that case, I was thinking of it of a different scenario, my answer was going to be different which was it's a question of let's say you had a bunch of historic videos that were not captioned for whatever reason.

They were up on your website. The question is how do I address that to make them accessible without breaking my budget? The answer could be what you do is you make an accessible list describing what all the videos are, and that accessible list is where it's posted on the public website for members of the public so that everyone going to the website has the access to the same information at the same time.

Everyone has to say, "I want video number one." When they do that, they requested to ask you for an accommodation or what they need to make that content accessible. That could help an agency to prioritize material which has historically not been made accessible.

Larry: I understand that. I should ask other people. Did that all make sense? Oh, I got one no. Just for giggles, what didn't make sense? I'll share it with the audience.

Audience Member: It just didn't make sense to me. I'm sorry.

Larry: Can we just take another crack at it?


Larry: ...I understand is not important.

Tim: We're both reading English, but because of the punctuation on the question, when I read the question, what I interpreted to mean was I have 360 discrete videos posted on my website which are not accessible.

For whatever reason, we posted a bunch of inaccessible content on our website. What do I do? My response was, the accessible approach would be to say, "OK, write up a description, accessible description of all of those videos, and post that accessible description with the link."

Bruce: Tim's first step is, yes, you take that...again, what we were saying, 360 videos, instead of this 360 video. The first step is, yes, you take the stuff down. If it's important enough to post, it's important enough to find the resources to make it accessible. If you don't have the resources to make it accessible, again, you've got to revisit the question, "Is it really important enough to post?"

Larry: Except that you grandfathered it.

Bruce: No, you're only grandfathering stuff that meets the original standards. If you don't have captioning and audio description, you haven't met the original standards.

Anyway, one approach that people have done -- usually it's paper documents, but it could apply to videos, too -- they've got this huge wealth of image-only PDFs that they can very cheaply post on their website. They want to, because they know there'll be some interested, some researcher some place that'll be interested in having these things.

For whatever reason, the optical character recognition is not going to work, or maybe it's all handwritten material. It was just originally scanned as image-only PDFs, and nobody's ever bothered to try and make these things machine readable. Now, it's 2017, and we can post these online for pennies, so why not just posted?

Because you're the federal government, and you don't just post stuff that accessible to people with 20/20 vision, and not accessible for people that have visual disabilities. You don't post stuff that doesn't conform to the 508 standards.

That equation that I put out there, I think it works in both directions. If it's important enough to post, it's important enough to find the resource. If it's not important enough to find the resources, it's probably not really that important to post.

We're in that second half here where you've got some stuff that you think's, you want to share it maybe it's with the news agency kind of stuff. I'm assuming it's archival, older material. It's not as time-sensitive as all that. You've got this huge archive of stuff you want to share with people in the public. You don't even know who in the public you want to share it with.

If it weren't for 508, you would just dump it online, but there is 508. We don't just dump stuff for some people and not for other people. Some of your researchers are going to blind folks by the way. Some of the people that you want to have access to this content may have a disability that prevents them from getting easy access to the way that's easiest for you to post it.

You're stuck in this [inaudible 54:53] where you've got this store of marginally-important materials, but you don't have the resources to make it accessible, so what do you do? You don't want to just sit on it because that's not being a responsible federal agency either.

What you could do is you can take a good inventory of the materials, a nice index. If it's video stuff, multimedia stuff, you could just have the descriptive identification of what each thing is. Then you put up a way for people to ask you for it.

When they ask you for it, you ask them to identify if they need captioning, or audio description, or a transcript, or OCR. Then you make sure that you've got in place a mechanism for adding those things upon demand pretty quickly. The idea is you're treating everybody in the public the same.

Instead of proactively dumping inaccessible stuff, you just put up a list of what you have and respond to them one-on-one. Again, remember the 508 just covers, as always since 2000, it's only the public-facing stuff. It's not the nonpublic stuff in those nine categories.

Probably your questionable, the stuff that you can't get the material, the resources to get captioned and audio described, it's probably not in one of those nine categories.

Larry: Sir, why don't we get a microphone for the gentleman right here since I think we're going to take some question, maybe a little impromptu.

Bruce: If we don't get to all of our slides, that's OK too.

Larry: I have to admit, I'm, without trying to be argumentative, I'm hearing this as I need a larger budget. Sir?

Audience Member: In the scenario you were describing booths, if I have, say, 50 products I want to product, 40 of them are OCR files that are not accessible. I do an inventory with descriptions of them and post that. Is it appropriate to identify in that inventory the specific 40 that are not accessible, and the reason that they're not?

In other words, do I give my customer upfront the information that I would give him or her once they contact me for one of those inaccessible files?

Bruce: Yeah, I think that's fine. The main idea is that 504 accommodations are not sufficient for your 508 obligations. As long as you're treating everybody the same, then you're fine. You put up the description. "This video does not have audio description or captioning. We'll add it if you need it," and make that sure that's a true statement. Then you don't release to one until you're ready to add those things on demand.

50 is not so bad. The people I tend to talk to, they have hundreds or thousands, or tens of thousands, of these old documents that they know there's some nugget of information in there someplace. Really, they just want to dump the stuff up for the public to digest. We're telling them the 508 rule doesn't really support that kind of idea.

You can apply the accommodations upon request under 508, as long as you've got the initial intake is treating everybody the same.

Larry: Seeing no more raised hands in the room, let's move onto that next slide.

Tim: Sure. Where are we? We were asking about transcripts. It says, "If after a creating a video" -- in this case, sight and sound, pictures and speech -- "with audio description, does that mean we also have to have a transcript available that includes a combined standard transcript with audio description intertwined?"

The answer really is no. There is not a 508 requirement for a transcript. A transcript isn't an alternative for either captioning or audio description. What this question seems to be asking is, if I've provided the accessibility of audio description, do I then have to caption that accessibility?

It's like, well, no, because the accessibility for someone who's hard of hearing is going to be to caption the speech. You've already captioned the speech. You're done with the captioning part in that video.

The audio description is for those people who cannot see. The audio description, you don't have to then caption that.

Larry: Now, if this question came from somebody who is using our website, there is a requirement to add transcripts to videos. That's on us for having made that decision. Look, if you've got a closed captioning file, it's super easy if you haven't.

Probably, you started with a transcript to get the caption file, so this is easy. If on the other hand all you've got is a caption file, it's a pretty easy process to pull out all the time code and just leave yourself with the words.

Again, of all the things we're going to talk about today, having a transcript is the lowest burden we're going to be talking about today. I've had no problem requiring transcripts from people. I feel no guilt about that, and it's built into our player.

If you go on, you bring up any post-produced video, you'll see a transcript button. You tap it once, the transcript magically appears, and it all works. Again. that's not strictly part of 508, but in the spirit of 508, because it's super easy to do, and can be a huge convenience to someone working with the video text itself, we did require it.

There are a couple things about that are not strictly 508-ish, but in the spirit of, you probably noticed, for example, in the upper right-hand corner of just about every page, there's a big, funky looking O.

That O toggles the open dyslexic font, which some people with dyslexia find is easier to read with. Not everybody does. Not everybody likes it, but it's optional. You click the button. You unclick the button if you don't like it.

That's not a 508 requirement. It's a thing we built into our website because we just felt like it. It seemed like some people would be helped by it. It was really easy to implement. I had no problem implementing it on

I understand that I think at, and possibly also the IG's website has an implementation of it. It wasn't hard to be nice, so we just did that. It just seemed like, within the spirit of 508, why not do it if you can? That was our logic on that one. I know it's not a rule, but we did it anyway.

Tim: I say Bravo to you. 508, remember, is a minimum. It's a floor. It's not the ceiling. If you guys want to shoot for the stars, I say, go for it. That dyslexia thing sounds really cool. I'm going to go check it out because one of the things in the revised 508 standards is a functional performance criterion for cognition, so I'm curious to see what your text does in that concept.

Larry: Just to set this up for, if you wait a couple months, we're going to add another feature. This is more of a research-based dyslexia solution, research that you can find online that's not wrapped in somebody's individual project.

That's changing background color to a particular taupe-y, cream color that's cited in, it's not a lot of research but there's not a lot of research on this. I've looked for where I could and we're going to implement that solution, too, because, again, it's an easy lift and why not help people? If it works for them, great. If it doesn't work, you unclick it and it goes away. No big deal.

I feel like there's a question in the back that I may have triggered. You want to pass the microphone, if you would, Mike?


[background conversation]

Audience Member: Your comment on the background.

Larry: It's a dyslexia thing. It's not a color blindness thing. But, if it helps...

Audience Member: There are people that are color blind, too, that may have trouble seeing something that you're referring to. I have run into that and had to figure out how to deal with it on my own. I've looked at websites and stuff to try to figure out, how do you make a graph for somebody who's color blind or a pie chart?

Larry: Yeah, that sounds hard.

Audience Member: It's hard. [laughs] It can be done, so guidance for that would be helpful, as well, I think.

Bruce: I should have had a slide on this, probably, this I Bruce again. That's one of the biggest changes that we get with the WCAG 2.0 is that there is now a minimum contrast requirement between texts, foreground color, and background color. Remarkably, somewhat, that was omitted from the original 508 standards when it does affect so many people.

It's really important to have that kind of thing in there. Then, if you look up colorbrewer, all one word, C-O-L-O-R-B-R-E-W-E-R. They have advice for making maps accessible for people with low vision and color blindness. It's a terrific resource. Again, it's not a requirement. It doesn't hit any of the 508 or WCAG 2.0 standards because WCAG 2.0 contrast requirement is only on text.

It's not on maps and other graphical elements because that's not as well refined, the minimum requirements. There's a lot of useful information and we've talked to lots of people at the park service about some of the many awesome things you guys are doing with your maps and trying to keep them readable.

The same things you do for low vision also means that you could put it on a low-quality copy machine and it resists losing information. It's pretty cool.

Tim: While we're waiting for more questions from the audience, let's just go through some of the slides. Another related question says, all of our social media sites are using closed captions and we upload extensive video descriptions. Oftentimes, more involved than the video and/or the actual video script. If I'm reading this right, wouldn't we, essentially, be captioning on captions?

Again, this is like we were talking about before. Audio description is voice narration added to benefit people who cannot see the video. The additional voice narration is not captioned because captioning is to benefit people who cannot hear the original audio track. Then, he says, you guys have chosen to create transcripts for everything, right?

Larry: Everything on I think it would be a bit of a lift to put a full transcript of...I'm not doing social these days but on Facebook, it might be inconvenient posting or Twitter. Honestly, photographs of texts, I just don't have anything to do with that. I can't do anything in 280 characters.

Tim: Let's keep going. Next couple slides. When the content is a speech or public presentation, what are the requirements for audio description in those cases? The answer is, maybe you don't have any audio description requirements through the WCAG 2.0 definition for audio description.

For those of you in the room, remember we talked about standards incorporated by reference. The Web content accessibility guidelines are a separate document, the links to which I found in our 508 standard. If you look at them, they have their own set of definitions, which are incorporated into the requirement.

The audio description definition in WCAG 2.0 says narration added to the soundtrack to describe important visual details that cannot be understood from the main soundtrack alone.

If someone's just giving a speech and that's all it is, it's just a speech of the words, perhaps there is no need for audio description because everything is contained in what the speaker's saying and you don't need to do additional audio description.

Going back to the discussion we were having earlier about the technical difficulty about adding another line for audio description, video description, one of the things that we've often found recommended is that, to the extent possible, speakers, especially when it's something when you're in government speaking, you should try to anticipate that whatever you are describing or discussing should be audio described.

If you're from an agency, you shouldn't be standing in front of a graphic going, "As you can see here..." and "Over there..." You should say, "This is a graph of wheat production in Nebraska in 1940," or something like that so that the people reviewing it will have some sense of what's involved.

Another idea, with a little bit of foresight and planning, to work the audio description into the transcript of the speech itself is something that has been a strong recommendation.

Let's bop through some more slides here. If there's audio and Internet video player, YouTube, Twitter, Facebook contains captions, does this meet the standards? Yes. There are other WCAG 2.0 success criteria that may be involved. If you go to accessibility, there could also be requirements for font size and so forth.

The captioning and the audio description are the bigger challenges when it comes to video. Remember, it isn't just providing the captioning or just providing the audio description. There may be other features that are impacted here, as well.

Larry: Let's talk about YouTube, briefly.

It can have captioning, so that would meet the captioning success criterion but it wouldn't necessarily meet the audio description success criterion unless there was a second YouTube video with audio description on it because there is no way on YouTube to just toggle on and off audio description unless you've embedded the audio description in the ongoing play-by-play of the event?

Tim: Right, unless you've already put it in the transcript.

Bruce: In that case, probably you'd have to do two versions of the video, one with the running audio description, and one without.

Larry: In some ways, we're discovering this is two different kinds of videos. There are these informational videos, which is somebody talking. That's easy, not a lot of description going on there, unless there are slides or something else going on.

Bruce: Very often. The only problem I see with those are the introduction slides. The title slide isn't spoken, or your speaker changes, and that's only a cue card that comes up underneath the person. It's just a little bit more.

Larry: There's a dynamic there, because let's face it, government presentations where everybody reads every word on a slide are notoriously dull.

Bruce: Like we're doing, right? Yes, yes, yes.

Larry: They're notoriously boring as all heck. I guess I'm going to say it out loud. We can be really dull presenters in the federal government sometimes, but the professional, high end whatevers who are making use of a single graphic or a word, and they're dancing verbally around the world, that's not as compliant.

Bruce: Yes, but how much more...If you just listen to a news broadcast, ignoring the little ticker down at the bottom, which is changing every two seconds, if you were to watch TV with your eyes closed, a news program with your eyes closed, you don't miss too much.

With a little bit of extra prompting, you wouldn't miss hardly anything at all. Those names that pop up that they never tell you who's speaking or their title, you only get that from watching the screen. I think you could have a very compelling video programs, and have them 508-conforming.

Larry: Then there's that other kind of video, which is more experiential. Let's say we've got the overhead drone shot of one of our many gorgeous national parks, and it's taking us on a tour of something. Maybe there'll be a word or two that pops up.

Bruce: Awesome. You were reading ahead, weren't you? Let's go to the next slide. I bet he wasn't.

Tim: It's the one after this.

Bruce: It's the one after this? Right, OK. I want to talk about the WCAG requirements, the 508 requirements, for other time-based media. Here's an excerpt from 121, "Audio-only and video-only prerecorded for time-based audio and prerecorded video-only media, that your prerecorded audio-only media has alternatives for time-based media provided."

That could be your transcript. "Your prerecorded video-only either has an alternative for time-based media or an audio track is provided." If you're talking about your experiential things, that might just be that, where you don't have a voice over. You've just got the drones flying through the beautiful national park with the background music going.

Then let's do the very next slide, slide 17, about the 2017 requirements for sensory experience. I'm excerpting from success criteria 1.1.1 for non-text context that, "All non-text content that is presented to the user as a text alternative that serves equivalent purpose."

I've got to say, this text alternative that serves equivalent purpose, that's a heavy lift for many things. That's hard to do. That takes some practice, but we've got lots of experience with doing that for static images on the Web, text alternatives that serve the equivalent purpose.

Then it goes on, "Except for the situations listed blow," and one of those situations listed below is sensory. "If non-text content is primarily intended to create a specific sensory experience, that text alternatives at least provide descriptive identification of the non-text content."

The descriptive identification is really all most people that are using screen reading technology are looking for a lot of times with these photographs and these really more artful kind of things. Descriptive identification is not nearly as hard as a text equivalent.

Let's go onto the next slide, with the related question for sensory experience. How are we supposed to share video B roll specific for scientific research? We have underwater video cameras. Drones have filmed thousands of hours of footage, and share those publicly so researchers can easily access the content.

Audio describing underwater or drone footage would cost hundreds of thousands of dollars each year. Yes, we had the same slide up 12 slides back. My point is that WCAG is a baseline. There is no requirement to add audio description to silent videos.

The baseline WCAG 2.0 AA requirement for this sort of thing, material, is just the descriptive identification. I think that's going to cover a lot of our situations. Again, 508 is a practical, day to day thing.

It's not really meant to be aspirational, as choked up as I got at the beginning of the program. You've got this drone flying this sweeping, beautiful thing through the Grand Canyon. If you don't talk about it, maybe that's all there is. You've made this most beautiful thing as dull as dirt. If it's a sensory experience, the baseline requirement is just for the descriptive identification.

Larry: Let's say I've got a thousand hours of footage of following a single sage grass, and it's silent. I can say, "A thousand hours of footage of following a sage grass."

Bruce: Yes.

Larry: Come on, we've all seen the video of the sage grass. Part of what makes them cool is that blurbly sound it makes that I'm not going to try to imitate, not where anybody who knows me can see me.

That's not silent now. That includes this blurbly sound. Do I now knock myself out of the ability to just say it upfront, or do I have to now fully audio describe this thing?

Tim: I would argue that the blurbly sound that the sagebrush is making, if you're intending to show it as, "This is the mating call of the sagebrush," then you could say, "Sagebrush, thousand hours of sagebrush emitting mating call."

Or you could say, "Thousand hours of sagebrush growls, cooing." In other words, if the sound is connected to something that you're trying to illustrate to your audience, so it's either communication or whatever, which obviously you're not going to capture, this cooing. It's going to be part of the sensory experience you're describing.

Larry: I guess I'm most safe if I'm not the one talking, and just letting nature talk.

Bruce: I think that would probably be a safe way to do this. I'm thinking about, if I was watching this on TV, what would be the captions I would expect to come out? I would expect to see 999 hours of wind whistling or whatever.

Then the bird makes a noise, and there'd be the little symbols pop up on the screen that tells you there's music playing. That would be the extent of the captioning. If this was really, would I really expect to have this audio described?

You know what? If you're willing to broadcast this thing for a thousand hours without any other talking, I guess it's done. [laughs] You can do that from the description of identification. That sounds like pretty raw footage to me, and it sounds like it's just a sensory experience. Twist my arm, and I think I agree with you.

Larry: I think this helps us a lot. Maybe I'm not 100 percent on this, but I think this has helped a lot of our bureaus right now. Why don't we go to a question from the live stream itself? Nate?

Nate: Erica Brown asks, "I know that we should be compliant, but I'm curious to learn more about the how-to. How do we implement the standards? Is a list of agency-approved tools we should be using to execute the updates?"

Larry: I guess that one's really more for me. Thanks for that, Erica. [laughs] There is not a single list. However, if you check out either your bureau guidance for this, or go to -- that's our digital media guide -- that can be somewhat helpful.

There's actually a refresh coming up on the DM guide soon. Off the top of my head, I couldn't tell you everything that's inside it, but there's guidance on closed captioning, a little bit on audio description, some on how to use the various social media services that we have accounts on, some super famous accounts on some of those things.

We'd like to keep them as close to compliant as possible, and keep as many people in our audience as we can. We don't constrain the bureaus particularly, as far as I know. We like folks to use tools that are legal to use, but we don't have a list of illegal tools, for example.

There's no master list, because frankly, a new tool pops up every day, and we haven't checked all of them. If fact, maybe that's something you want to do. Make a recommendation or pass it up through either your social media coordinator, or the person who is on the Web council for your bureau. Either one of those would be a fine way to go.

That's a good question. Thank you. Nate, any others in the feed there? If there are any more, just flag me, and we'll bring them up. Let's take more of the email questions.

Bruce: Oh, hi, sorry. Sure.

Tim: Hold on. If we could have a microphone for the speaker in the audience, please.

Bruce: Right here in the front. You're on.

Audience Member: What would be the threshold for audio description? If I were describing you all, would I say three men sitting behind a table presenting a panel, or would I have to go further and say the man on the left and the man in the middle have a right shirt, the man on the right and the man on the left wear glasses? How far do you have to go?

Tim: Good question. You're asking about where you take the audio description. Remember, the purpose under 508 here is to provide information necessary for the comprehension of content that you couldn't otherwise get.

In this case, if it was important to know that two people were wearing eyeglasses, and one person wasn't, if that was important for some reason, then you would mention it. Otherwise, it could run the gamut from describing our clothing that we're wearing, to the fact that we're just talking heads, or three panelists whose names are...It really depends on what the purpose of the visual image is.

Bruce: I always advocate a very light touch for both your text equivalents that serve the equivalent purpose and audio description. Talk to people that are consuming the media, and less is more most of the time.

Larry: That reminds me of something. You can't see him. Sid Sharma's here in the audience, too. Sid taught me something a long time ago. He said, "When someone is using your website who has some kind of a disability, this is not their first rodeo."

They didn't just magically show up on or having never visited anything on the Web before. It's not our job to treat people who, hey, I have a visual issue. I have to wear the glasses. I'm sure I'm going to need even better glasses as I get older. I know I'm losing my hearing. I used to be a DJ. Oops.

We all have some issues, and they tend to get worse over time. Again, we adopt coping techniques of our own. Everybody who's doing anything has some kind of a technique they use, whether it's tilting their head a little to the side to hear, or looking through which part of their glasses is appropriate when trying to read the website.

Building your website to accommodate someone who maybe isn't going to get the video and the audio fresh out of the box without some kind of help, that's one thing. There's no need to treat them like they've seen anything like this.

It's not a "them," by the way. I just have to use a word. Basically, it's don't treat me like an idiot. Just let me be able to make my font bigger. I can deal. I have my coping mechanisms. Everybody's got some kind of coping mechanism.

Acknowledging that, and saying, "OK, all I need to deal with is, how do I help people as best I can?" That's from before we did the 508 refresh. I'm hoping that guidance still applies.

Tim: Sure, absolutely. I'm just keeping an eye on the time. I guess the question is do we have more questions from the floor? Do you want to go through the rest of the slides really quickly?

Bruce: We could do the two question slides like we skip to 35?

Larry: Let's do that.

Bruce: The fundamental questions are how far and what means do we have to go? I've read the act and nowhere does it specifically mention how to out-tech the accommodation. I think that's where we're at. I meant to send you over to slide 31.

Question about undue burden. This seems like an undue burden that is going to drastically increase the complexity and expense of producing videos. The site we have, you got to be a little bit cautious with saying something is an undue burden because that's all mixed in with case law. It refers to the agency resources.

Don't just dismiss undue burden based on your impression of the amount of work. It may mean that you have to ask for more resources or walk it up the chain of command, as you will. There is also something called fundamental alteration and the five weight requirements around that, historically, and with the revised standard are a little bit more lenient.

We had hoped to go through those slides but look up fundamental alteration.

Tim: Bump up one slide.

Bruce: It's a little bit more modest.

Tim: There's fundamental alteration, Bruce.

Bruce: I want to get to the one other question.


Larry: Since we do have the five minutes, why don't I just ask a quick question? Let's say that YouTube didn't have a closed captioning button on it.

Bruce: There we go and this used to be a big issue before. [inaudible 83:48] maintained their use, but the other thing is the 508 has always deferred to the agency business need. In addition to the fundamental alteration, which is a reasonable assertion to make, there's also the issue with commercial nonavailability, what we call best meets.

You're using YouTube because that's where the public is. As a federal agency, you want to be responsive to the public. That's commercial nonavailability. You have to use the thing that's out there. Facebook is a similar kind of thing. You do everything that you can on the platform. That's best meets. That's meeting 508.

Even though you have something that's maybe not as accessible as you know it would like to be but it's still best meets. I think we're getting a question from...


Larry: As a clarification. Let's say there was some other squirrely little website somewhere that, literally, nobody in America went to except 508 coordinators, you wouldn't be saying fire YouTube and go and put all your stuff on that website nobody goes to?

Bruce: Right, because that's not the agency business need.

Larry: Just checking.

Audience Member: Hi, Bruce, Tim. It would be helpful for the audience if you explain what fundamental alteration and commercial non-availability is, please.

Bruce: Sure. That's slide 32. This is E202.6, "Undue burden or fundamental alteration. With revised standards as compared to the original." We put in a few more sentences just to provide some clarity. We haven't really changed anything but we treat them side-by-side except for the mention that undue burden is all agency resources.

This is for fundamental alteration. Where conformance would result in a fundamental alteration in the nature of the ICT. Conformance shall be required only to the extent that it does not result in the fundamental nature of the alteration. There's two sub-revisions, required documentation in alternate means. Let me go ahead and read those very quickly, 33.

Next slide. 206 -- required documentation. The responsible agency official shall document in writing the basis for determining that conformance to the requirements in the revised standard 508 standards would constitute undue burden on the agency or would result in a fundamental alteration in the nature of the ICT. Document it, in writing, for your notes or your supervisor's notes. That's all that is.

The documentation shall include an explanation of why and to what extent compliance with applicable requirements would create an undue burden or result in a fundamental alteration in the nature of the ICT. We rope those in together because the work you have to do, the required documentation and also providing alternative means, which can be an accommodation after the fact that does the best you can.

Per the statute and per the original 508, they're all mentioned in the same breadth, so with the revised standards, we are just a little bit clearer with that.

Tim: E202.7, which occurs right after this, is best meets. It just says, "Where ICT conforming to one or more requirements and the revised 508 standards is not commercially available, the agency shall procure the ICT that best meets the revised 508 standards consistent with the agencies business needs."

This is a restatement of what you already have in the existing 508 from 2000. This also has documentation requirement and it also has alternative means. For all of these exceptions that we just talked about, you can't just assert it. You also have to document what you're saying and you still have to provide access in some way.

Larry: I'm looking at the clock and I'm seeing we're about 20 seconds before 3:30...

Bruce: Go to slide 37 because that's also related. It asks about...

Larry: Did you guys have a half hour extra because I could easily say, I'm perfectly willing to pay the captioner for another half hour of their time. If you guys have the time, I will take the time and I'm happy to run the credit card for another half hour.

I got at least one nod out of the office. Are you guys OK with that? Mike, can you handle another half hour?

[off-mic comment]

Larry: Sorry?

[off-mic comment]

Larry: We could ask them. Let's see what happens. Thank you or get the captioner to pop into the caption with, yes or no, I'm not free. I'm cool with that, either way, because I am perfectly willing to run the card for the next half hour. If you happen to see the captioner pop up with, "Yes, I'm free," let's just call it.

In the meantime, we'll just continue as though things are going and if the captioner stops, we'll certainly know that and call a halt to this because you know we're not going to do a live video without captioning. Why don't you guys continue this? What slide did you want me on?

Bruce: Slide 37, I think is really related to this commercial non-availability stuff. They mentioned a couple products. The technology to make Adobe Illustrator drawings or Photoshop pictures compliant does not exist natively. When we put an illustration or photograph into InDesign, we add all texts that can be read back by Acrobat.

Webmasters can add all texts to drawings and illustrations, so you have their HTML code and their Web page compositions. That's fine. The requirements under 504 authoring tools are qualified and limited to what is supported by destination format and the commercial non-availability clause meets into this, as well.

You've got a legitimate business need for using Adobe Illustrator, or Adobe Photoshop, or this InDesign, those aren't public-facing. Those are software that's used internally for good, sound agency business reasons. 508 doesn't obligate you to try and develop software from scratch.

You find the tool that's most compliant, that meets your business needs, that meets most of the 508 requirements, that's the one you're allowed to perform and your agency is conforming with the 508 requirements. Then, of course, any pressure you can put on Adobe to make their tools better is all great. They're doing a pretty good job with accessibility, overall.

Larry: For those of you who have seen the Web page, 508 accessible videos -- why and how to make them. There are some caveats on there and they're actually not listed here anymore. I have them if you want to...

Bruce: We can switch over to your slide deck now.

Larry: I have this other slide deck with fully fleshed out questions and answers, so let me just grab that and see if I can't...Let's see if I can turn this one off.

[background sounds only]

Bruce: I apologize. We're usually so good about staying on schedule. Just talk faster.

Larry: Apparently, I'm not getting the zoom on the slideshow. Come on, now. Work with me. This was supposed to be a slideshow before the whole changing things. [laughs] Here we go.

For instance, internal videos, videos used internally, one-time basis for training, rented videos, etc., but the program manager is still responsible for offering and providing reasonable accommodations and uncut footage, rough footage, or B-roll, I guess in this case, it would be to send out to reporters rather than posted on the website but I'm not sure about that.

Should we label it unfinished and not in its final form? How can we use either of those?

Bruce: During the refresh, we did get requests to consider draft content or some other scoping for, maybe, if things aren't widely disseminated. It wasn't just the people at the access board, which is just a few of us. It's a very small agency. We had a working group with representatives from five, six agencies, all with pretty, very advanced...

Tim: We had an internal, federal review committee, which was called the ad hoc, which was the federal agencies reviewing the proposed 508 tasks. What Bruce is saying is we discussed a lot of the operational issues with them.

The agencies within our group varied in size from micro agencies, like ours, to extremely large agencies with hundreds of thousands of people who have different layers of vetting that they have to go through. A lot of the stuff that we talked about, we ran it through the filter of, how would this work out, operationally, as well?

Bruce: The best we could do, and we also had feedback from the public, that 508 should apply to everything, all the time. We're not writing aspirational requirements. We're writing requirements that we actually expect agencies to enforce and use every day for the things that are scoped in. The official agency communications is where we drew that line.

For sharing with news agencies, my suggestion would be to come out with some sort of process for vetting these materials that you're putting out, so that -- one, it's not public-facing because when it's public-facing, we're pretty clear that if it's videos, we're expecting captioning and audio description. You're talking about news events that are breaking. It's all time sensitive.

There's no 508 general exception for timeliness or...What's the other one we get about? First responders? Fitness for duty? We stayed well clear of that. One of the examples I've gotten over the years is, we have our video here on training people firearm safety. We're not going to be giving firearm safety to anybody who's blind. Why do I have to make this firearm safety video accessible?

My answer is, because you have people that are blind that might need access to this information. Deaf, as well. Yes, your average person being issued a government firearm probably is not blind.

It's not hard to come up with scenarios where you've got an instructor or a senior supervisor who maybe used to be a firearm specialist, who lost their sight, and now, you'd like them to be able to contribute to either managing people or knowing that the video is not totally off track. They're a subject matter expert who lost their sight or lost their hearing or lost their ability to use fine motor mouse kind of things.

Why would you not keep making that resource available to everyone in your audience? Just because of the nature of the video or the nature of the material or you've never gotten the request before, none of those are, really, very compelling reasons as to why you shouldn't do the 508. I was going somewhere with this.

I would think for this kind of news thing, that you do set up -- it can be a very lightweight registration process -- but, my suggestion is that the videos themselves are not public-facing and that you have some sort of login thing...It's not very well restricted.

You said you wanted to make it available to bloggers, for example. Why couldn't that be a blind blogger out there in the YouTube land? Figure out who...

Larry: When you say we're going to add in the requirement for footage, I'm never going to be able to immediately turn stuff like that over and 508 it. You know that, right? It's not an instantaneous process.

If someone is in the business of news gathering and then, turning it back over, I've got to assume that they've got processes that they've used on videos other than ours. I'm going to wear my glasses. I don't know how to make that work and feeding the press rough footage, which they want, and they're all part of the press.

I don't want to be in the business of deciding who's press and not press. Maybe I should be in that business but I don't think so. I'd like to stay far away from that one.

Bruce: My opinion or orientation on this is oriented from decades of...As long as it's been available, I've been watching TV with captioning. I know that the three letter network agencies all can do captioning on live events. I can tell you, it's pretty marginal quality a lot of the time. [laughs]

If you're giving raw video to a professional organization, you can ask them, when this becomes public-facing, you're going to add captioning to this? That's part of your deal with them. They'll say yes because the SEC has been forcing these people to live caption their news programs.

Larry: Let me put this to you. I don't think we have the ability to tell someone, "No, you may not have this government record if you choose not to behave this way with it." I think that would be a violation. I bet the FOIA people would back me up on that.

Bruce: Talk to your lawyers about which thing trumps...Is our records management stuff and our due diligence to what we're sharing, can that really take precedence over 508? I think that's a lawyerly question but I don't think the answer is yes.

Larry: Tell you what, I know Nate has a question from someone in the field, two questions. Let's take one at a time.

Nate: We have two questions, both of them dealing with internal 508 compliance. The first one is asking, InDesign templates for visual information specialists, if those need to be 508 compliant? Of course, the final products would be compliant but this is for internally. Do those need to be 508 compliant for employee use?

Tim: Could you repeat the question because I don't...

Larry: Nate, could you grab that one again?

Nate: Sure. It's just asking about, basically, internally, templates for InDesign for an Adobe product. Should those be 508 compliant? It's a software program used to create, basically, print and...

Larry: Not the final result but one of the ingredients you would use, let's say, a designer makes a template and that all of our whatever are going to follow this template, does the template itself have to be 508 compliant?

Bruce: One of the things that's new with the revised standards as compared to the original standards is that we have some new requirements around authoring, specific to authoring tools, which is, basically, anything that's used for content creation or editing.

The requirements, specifically, for templates is in 504.4, "Where templates are provided. Templates allowing content creation that conforms to level A and level AA success criterion and conformance requirements in WCAG 2.0 incorporated by reference C702.10.1 shall be provided for a range of template uses for supported features and as applicable to file formats supported by the authoring tool."

I'm going to repeat part of that now. Accessible templates should be provided for a range of template uses. No, not every template but a range of template usages. Then, supported as applicable to file formats supported by the authoring tool.

Now, I've got a colleague that uses InDesign but I don't use it myself. Yes, some of the things that InDesign does are not as great for accessibility as perhaps they could or should be.

The 508 requirement, per se, is really pretty minimal, in that, it's not saying every template. It's saying a template for a range of uses. Ask Adobe if they think their product meets that requirement. They'll probably say, "Yes."

Internally, as a matter of practice, if you, as an agency, can create your own templates, that's going to save somebody a lot of work down the road but that's not, strictly speaking, a 508 requirement.

Larry: I'm going to take that second question, Nate.

Nate: Also, an internal question. Would an internal SharePoint website have to be 508 compliant? If it was a SharePoint with PDFs, would they need to be compatible with screen readers and would photos and images need all text?

Larry: Just to be clear. We're not talking about a SharePoint list of files. We're talking about an actual intranet website that happens to be hosted on SharePoint? At least, for purposes of answering the question, I'll take it that way. Does that make sense for you, gentlemen?

Bruce: Yes. We get this question about SharePoint a lot. I wish there were easier and better answers. The intranet site is covered by 508, original and revised standards. That's one of the reasons we went with the revised standards.

The original standards ended up netting up everything much more than it was ever designed or expected to because we moved from having network sharing file sharers to using Web-based interfaces and Web-based email. It was really scooping up a lot more stuff than anyone really anticipated, we think. That's why this agency official communication is so important.

The intranet site, the SharePoint site, the interface for all that needs to be accessible. The thing that gets a little bit iffy-er is that, of course, Microsoft and Adobe II are trying to erase the difference between desktop applications and your Web experience.

If you click on a link to a Word document that's not in one of those predetermined categories of agency official communication, that Word document might actually show up inside your Web browser, probably Microsoft Edge or Internet Explorer and you're really in a Web browser. You're not in Acrobat. You're not in Word. You're still in your Web browser.

That's not the fault of the document. The document itself is only covered if it's in those categories of official agency communication, or if it's public facing. That applies to your Word documents, your PDF documents.

Now, if you're implementing them in SharePoint in ways that are forcing them to [inaudible 102:58] in the browser, that's where it starts to get a little bit muddled, because Web content designed as a Web page is covered, but these other random documents are not covered.

All those legacy things that were again, not in those categories, not updated, not affected, but your SharePoint site very much is covered. That's a long answer to what seems like a simple question.

Larry: Since we're here, I have the questions from the physical present audience? I thought David might have a question.

Audience Member: I'm trying to think of which one I want to go with. Let's take the video question and audio descriptions. When we create a video to convey information, the video is the vehicle for conveying the information. If I were to try to convey that information without a video for an audience that knew could not see a video, I would probably convey it in a much different way than I did when I created the video.

The true alternative, for me as someone trying to convey the information to the video product, would not be the video product with additional audio descriptions. It would be another produce altogether that would be built, from the beginning, as an audio product.

My question is whether that approach is acceptable under 508.

Bruce: Yes, if you're able to do that second thing, absolutely. WCAG 2.0 has something that's called a conforming alternate version. That could come into being invoked a couple different ways. One, you're talking about doing something additional and robustly, and for a different audience. The authors of WCAG 2.0 didn't want to disallow good actors from doing that kind of thing.

There is something called a Conforming Alternative Version. I have WCAG 2.0 with me, but I don't think I want to read the definition of that.

The conformance requirements in WCAG, one of the things I point to, is that it allows for a conforming alternative version. By having a conforming alternative version, you're conforming to WCAG, so yes. You would be able to do that.

Larry: Bruce, I imagine this is helpful when it comes to say in maps. You wouldn't...

Bruce: A map I think we don't know how to make it accessible. I think people tend to do the most they can, which is providing the data in some sort of raw format. We resort to maps and other visual interfaces because we simply don't know how to represent the raw data in a way that's accessible.

Larry: Sometimes we do it because maps are pretty.

Bruce: There you go.

Larry: If what you're doing is showing...We have elections periodically. Someone will throw up the electoral college votes, or maybe we'll do populations. We'll have a map and all the state populations will be on the map. That's a visual way of representing how many people live in Montana, but the map is not the data.

The data is that state has X number of human beings living in there, and that could be a table. If I provide that to someone, that really is the same data that we're delivering by the map. It's just less fan. I can't deliver fun sometimes. It's cool to look at a map. They're colorful, they're pretty.

You get all the edges, you get all the little fracto that is the shoreline. I don't know how to really convey that in poetry or all text, but I can give someone a table that shows what state and how many people live there. If that's doable, does that sound like an acceptable way of representing the thing that the map is representing? If that is actually what the map is representing.

Bruce: With that example, I don't even think you need to resort to...there's some hesitation for people to label their things as conforming to alternate versions, which is why I'm going down this way. I think what you described where you're making your data available, I think that is text that serves the equivalent purpose.

I think you're meeting the toughest requirement in WCAG 2.0, 1.1 for non-text context. I think you're fulfilling that on its face by providing access to the raw data that's driving your infographic thing, whereas the conforming alternate version is really a whole different Web page for the inaccessible Web page.

It's a whole different...maybe it's a recording for the video. That audio description isn't really making the case. I see a little bit of a difference between those two approaches. They are both permitted under WCAG 2.0 [inaudible 108:07] .

Larry: I'm sure there was a second question in there because it sounded like you were making a choice.

Audience Member: The one about the video was really because when we think about the widest applicability for the products that we create and sometimes the audio rather than an additional audio component to a video, if you think about it as purely an audio undertaking, an audio product, then it has applicability as a podcast.

It has applicability for people to listen to as they're driving their car down the highway. It becomes then another product that has its own life. The other question I guess that was coming to mind, it actually had to do with maps. It seems like there are instances particularly in some of our more complex PDS where we're describing things like the range of a species and so forth.

That any sort of tag that we may apply to map does not really convey the kind of cannot convey all the information that is contained within the map. It can't show how a free-form line...distinguishing what's within a range and outside a range. I can't convey that textually.

I convey that over the phone in talking to somebody. I can probably convey the information that someone would want to know like, "Does this arrange cut through my property?" more easily via conversation than I could via any sort of text, or table, or anything like that.

I'm wondering to what extent we can rely on things like that as a means of conveying the information when tags, and tables, and things like that just can't cut it.

Bruce: I think that's a very practical and fully conforming meets the intended purpose. It's a very sensible approach, and it's following the letter in the spirit of the 508 Statute and of the 508 requirements on its phase. That is frequently one of the things that the technical assistance we give out...when you're adding a picture into the middle of your document, think about why you're adding the picture.

If the picture is coming right before or after this long texting narrative that you think is less interesting but has all of the same as information to the best of your ability, you're done. All you have to do is provide the descriptive identification of the picture because you've already got all that stuff in the body of the document so that you're fine.

It's when the picture is really substituting, or the illustration is substituting that's providing unique meaning, it's substituting for something that you've forgotten to put in writing. That's fine. Again, a picture is worth a thousand words. The questions you gave I think are great.

That's the difference between a text equivalent or a textual description versus having somebody on the phone, is the person on the phone is interactive. You can figure out what they really want to do. When you're doing the text alternatives or the text descriptions, you don't have that benefit.

You've got to try to plan ahead all of the questions. Does this property line cut through my property or not? Aside from doing that as an illustration, and where maybe the person can figure it out or maybe they can't because they don't really know how to read a map, they may be able to look at the data that's driving it or they would ask an expert.

Hey. The expert or the person asking the question, you don't know if they've got a disability or not. As the document author, you don't have to try and figure out every scenario.

Larry: Maybe the last question is online? I'm glad you decided to spend the extra time.

Nate: Microphone.

Larry: I should turn my mic. I should turn my microphone once again. Nate tells me there are no more questions available online. We've got about five minutes left on our closed captioner. I'm glad we decided to spend the extra few minutes here because we've gotten some really good questions from the audience. That's half the fun.

Tim: What I'd like you to do, can you go back to our written presentation because we'd like to put up some resources.

Larry: I can try.

Bruce: While you're doing that, one of the things I'll mention is that 508 compliant or not, has come up a long time in the community. There are some new resources now being published at,, collecting some of those thoughts.

There's a good bit of consensus about what makes an accessible PDF, what makes an accessible Word document. We're working on PowerPoint, we're working on Excel. There's this group called the Accessible Document Community of Practice.

Good, so we've got...This slide is about the W3C-Resources, which are not particularly federal government, but they are fantastic. The quick ref database, slice 41, is really the day-to-day thing for the developers.

The thing I've been talking about for the moment is slide 44, which has the...Wait, where's the? Oh, slide 45, sorry., which has all these best practices resources that have been put together by this community of practice.

Now, there simply weren't enough people to do things like Illustrator and Design, but there were plenty of expertise to draw from to get kind of consensus around things like Word and Excel and PowerPoint and Acrobat. A number of those kinds of questions have been pretty well-addressed.

Tim: What I'd like to point out is this revised 508 Standards Refresh Toolkit, which is at the A lot of the work product done by these intra-agency working groups is called Section 508 Transition Team.

They're going to be posting a bunch of new material, particularly this week, because this Friday, I think it's the 13th, Bruce and I are going to be at General Services Administration. There's a day long intra-agency 508 conference.

The entire day we're going to be talking about the refresh standards and new 508 resources, including not only understanding the standards, but comprehending them, best practices for establishing 508 departments, best practices for creating accessible documents, like Bruce was talking about. It's very good.

All of this material is going to be posted at the website under the Revised 508 Standards Refresh Toolkit. That's something to check out. It's generally called 508 Transition Guidance. You'll find it very helpful.

Larry: All right, so that seems like it's about it. Tim Creagan, Bruce Bailey, thank you for your time and answering all these questions. I had a good time. I hope everybody else did too. Let's call this a wrap and enjoy the rest of our week.

Tim: If you wouldn't mind advancing our contact information on the last slide.

Larry: That one?

Tim: The very last slide is our contact info.

Bruce: That was it.

Larry: Contact info. All right, then it's a wrap.

Tim: That's our 1-800-872-2253, and we have a TTY, 800-993-2822. We also have an email for 508 questions,

Last edited 9/29/2021

In January, 2017, the U.S. Access Board published its “508 refresh,” the big shift in accessibility rules across the federal government. With the new rules come new complications. People across the Government have been wrestling with some of those complications -- and frankly, it was time to call for advice. We asked two of the Accessibility world’s gurus to join us for a consult and we shared the floor with you.

In this recorded session, Tim Creagan and Bruce Bailey provide a brief presentation on the Section 508/WCAG 2.0 requirements and field audience questions. If you’ve got web or social media responsibilities, this Q&A is for you.