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Toolkit Overview

Toolkit Table of Contents

Introduction
What is Section 508?
What is the Link between Section 508 and Quality Assurance?
What is the difference between Section 508 and providing reasonable accommodations to a person with a disability?
How does this Toolkit help with Section 508 requirements for EIT?
What about contracts, purchase orders, micro-purchases and Section 508?
How to Use the Toolkit

Introduction

Working together, EPA's Office of Environmental Information Section 508 Coordinator and Quality Staff developed the Section 508 Toolkit. The intent of the toolkit is to help stakeholders (EPA staff, contractors, developers, etc.) address Section 508 throughout the project life cycle – a critical component of Quality Assurance.

The toolkit provides suggestions, standards, links, and resources to consider or use while planning and developing a variety of projects that involve electronic and information technology (EIT). There is no one size fits all tool that will meet all of your Section 508 needs. Every project has its own technical requirements and considerations. And not all projects involve Section 508. It is important to remember that Section 508 only applies if there is electronic and information technology (EIT).

Mentioning 508 in passing at the beginning or waiting until the last minute of the project only increases the chances that a project will not be 508 compliant. Suppose you were planning to remodel your kitchen in your home. You wouldn't just tell a contractor to start work without some planning and careful consideration of what you want your kitchen to look like when it is finished! You would need to think about your budget, expectations, specifications, timeline, etc. This concept applies to your electronic and information technology services or products, as well. It is not enough to tell a contractor, colleagues, and other stakeholders to make something 508 compliant and just assume it was done. It is our hope that this toolkit will provide you with the resources needed to integrate 508 into your project life cycle from the very beginning.

The Section 508 Toolkit does not replace official federal Section 508 documents and guidelines. Furthermore, this toolkit is intended to be "living document" and updates will take place periodically.

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What is Section 508?

Section 508 of the Rehabilitation Act of 1973 (as amended in 1998) requires all Federal Electronic and Information Technology (EIT) developed, maintained, procured, and used after June 21, 2001 to be accessible to federal employees and members of the public with disabilities. The US Access Board, an independent federal agency that focuses on accessibility issues for people with disabilities, is responsible for the Section 508 standards.

Section 508 requirements only apply to"electronic and information technology" or "EIT". Electronic and information technology includes any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information.

Some examples of EIT include, but are not limited to:

Section 508 applies to all EIT even if there are no employees with disabilities in the office, branch, or even an entire AGENCY. It is important to note that there are exceptions under Section 508 depending on the nature of the project, as well as the technical requirements.

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What is the Link between Section 508 and Quality Assurance?

Arrow Diagram of the ISO 9001 PDCA ('Plan-Do-Check-Act') circular process model

Ensuring that your product and or service are 508 compliant is a key part of developing deliverables of Quality. To help ensure your products and services are 508 compliant, this toolkit is designed to be compatible with quality management system requirements. When you use this toolkit, apply the ISO 9001 PDCA ("Plan-Do-Check-Act") process model.

Users of the toolkit should follow the four PDCA steps to ensure that the EIT project or service being procured or developed is 508 compliant:

Plan: Establish the objectives and processes necessary to deliver results in accordance with customer requirements and the organization's policies

Do: Implement the process on program specific activities

Check: Monitor and measure processes, products and services against policies, objectives and requirements

Act: Take action to continually improve process performance.

PDCA is not just a four-step process that you follow once and then you are done. It is iterative and continues throughout the project's life cycle. The cyclical nature of the PDCA model guides the project towards optimal performance, or for the purposes of this toolkit – 508 compliance.

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What is the difference between Section 508 and providing reasonable accommodations to a person with a disability?

Section 501 and Section 504 of the Rehabilitation Act of 1973 cover reasonable accommodations for an individual with a disability that is either an applicant or already works for the federal government. Section 508 is a different mandate from 501 and 504. Reasonable accommodation is the removal of a work place barrier for people with disabilities to allow them the opportunity to apply for employment, perform the essential functions of a job or, to enjoy equal benefits/privileges of employment. Whereas, Section 508 was enacted to eliminate barriers in information technology.

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How does this toolkit help with Section 508 requirements for EIT?

Use the toolkit when your product or service involves electronic and information technology (EIT). If there is no EIT, then Section 508 does not apply and the toolkit is not applicable. It is important to note that some projects, such as a conference, may involve multiple types of electronic and information technology, so plan accordingly.

Using the PDCA model, the toolkit provides Section 508 standards, example statement of work language, and a variety of resources for different types of electronic and information technology. The toolkit will help you ensure that your project will be Section 508 compliant throughout a project life cycle.

This toolkit will help you:

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What about contracts, purchase orders, micro-purchases and Section 508?

Section 508 requirements apply to all contracts, purchase requests, and micro-purchases. It is recommended that EPA requiring officials and contracting personnel include a statement about Section 508 and deliverables in contracts above the micro-purchase level of $3000 along with specific requirements for 508 depending on your technical needs. This will help to ensure that the requirement to purchase accessible EIT is addressed in all EIT-related contracts and purchase orders.

Suggested general Section 508 language:

As described in the Federal Acquisition Regulation (FAR) Part 39 Section 2, the contractor shall provide electronic and information technology (EIT) deliverables that are compliant with applicable Section 508 standards and requirements. For more information about Section 508, please refer to the Access Board site on Section 508 Standards (http://www.access-board.gov/sec508/standards.htm). For further information regarding EPA's policy on purchasing accessible EIT, please refer to CIO Policy 2130 (formerly 2100.1) Accessible Electronic and Information Technology. All information technology/information management policies can be found on www.epa.gov/irmpoli8.

Where, how, and when to use this suggested general Section 508 language is addressed in the life cycle project plan outline, described in the "How to Use the Toolkit" section.

 

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How to use the Toolkit

The toolkit has a two phase approach for achieving 508 compliance. Phase one of the toolkit will help you address four fundamental questions regarding Section 508 and EIT. The second phase of the toolkit has two parts – one, a life cycle project plan and two, a checklist of common 508 issues associated with particular types of EIT. The two parts of phase two are meant to work in conjunction. For example, as you develop your project using the appropriate life cycle project plan outline, the checklist can help prompt language you might include in your statement of work or technical direction.

Phase One – Getting Started with the Toolkit

Phase one of the toolkit has four questions that you should ask as you start planning and work. The answers to the following questions will help guide you through the 508 compliance process.

  1. Is the product or service electronic and information technology (EIT)?
  2. Do any Section 508 Exceptions apply?
  3. Will the EIT pose an Undue Burden to the AGENCY?
  4. What Section 508 Standards Apply to the Product or Service?

Phase Two – Ensuring 508 Compliance for Your Project

Part One - Life Cycle Project Plan Outline
There are outlines for each different type of EIT product and service covered in the toolkit. What outline you will use depends on the answers from Phase One - Getting Started with the Toolkit. The outlines combine the PDCA model and Section 508 resources. The outlines are designed to help guide the overall iterative life cycle of the project. Below is a general overview of the Life Cycle Project Plan outline format.

PDCA Steps Product or Service
Plan: Establish the objectives and processes Establish the objectives and processes necessary to deliver results in accordance with EPA's Section 508 requirements and policies.
  • Identify type(s)of EIT components. Some projects have multiple EIT, ex. a conference, web-based training, etc.
  • Determine if Section 508 Exceptions apply.
  • Determine which 508 standards and requirements apply.
  • Outline framework of project and identify 508 milestones, standards and requirements for project stakeholders.
Do: Implement the process Implement the work needed to complete the project.
  • Create solicitation bid, if applicable along with suggested general Section 508 language.
  • Develop statement of work (SOW) or technical direction (TD) with 508 requirements and milestones.
  • Create product.
Check: Monitor and measure for compliance. Monitor and measure processes, products and services against policies, objectives and requirements for Section 508 compliance.
  • Ask questions during development and key project milestones about 508 compliance.
  • Periodically test for 508 compliance.
  • Use checklists to monitor and measure process.
  • Identify if Section 508 Exceptions apply (Commercial Non-Availability or Fundamental Alteration)
Act: Execute continual improvement Take action to continually improve process performance.
  • Check in with the process – assess 508 compliance
  • Take additional steps as need to correct potential problems, ex. modify SOW or TD to clarify 508 requirements.
  • Manage close out and archive process (documentation) so that others benefit in the future from your work.
Additional Notes or Resources This section provides additional background information such as definitions, training, US Access Board guidance, and other tips.

Part Two – Checklist
Each type of EIT included in the toolkit has a checklist identifying some of the most commonly occurring accessibility 508 issues. The checklist is designed to be used throughout the life cycle project plan to highlight potential 508 issues that are common and can be addressed in project planning, what to look for when testing for 508 compliance, and 508-related questions to ask when communicating with project stakeholders.

This checklist can be used several ways throughout the life-cycle of your project:

to highlight potential 508 issues that can be addressed during project planning;
to test (or items to have tested) for 508 compliance; and
to ask 508-related questions when communicating with project stakeholders.

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