Section 508 for Vendors
Providing Products and Services to the EPA
The information below is specifically for vendors or anyone who wants to provide products or services to the EPA. Section 508, also referred to as digital accessibility, is ingrained in everything the EPA does - inside and out.
Delivering products and documentation that are digitally accessible is key to making sure that everyone has equitable access to information. A vendor's deliverables should conform to Section 508 standards; this means that documents, spreadsheets, presentations, websites, software, and training videos all need to be Section 508 compliant when delivered to the EPA.
These activities are in direct support of EPAAR 1552.211-79 (c) which states: Section 508 requirements (accessibility). Contract deliverables are required to be compliant with Section 508 requirements (accessibility for people with disabilities).
The EPA Contracting Officer shall insert the clause at 1552.211-79, Compliance with EPA Policies for Information Resource Management, in all solicitations and contracts.
As vendors, you need to know EPA representatives will ask for an Accessibility Conformance Report (ACR) as part of our market research. If you are unfamiliar with an ACR, please read the sections on Voluntary Product Accessibility Template (VPAT)s and ACRs.
On this page:
- Acquisitions at the EPA
- Accessibility Conformance Report (ACR)
- Voluntary Product Accessibility Template (VPAT®)
- Vendor Responsibilities for Content Creation
- Federal Acquisition Regulations References
- GSA's Guidance
Related External Materials:
- Electronic Code of Federal Acquisition Regulations (eCFR)
- DHS Trusted Tester
- GSA's Section 508 site
- Web Content Accessibility Guidelines (WCAG) and Technical Standards
Acquisitions at the EPA
The EPA Office of Acquisition Solutions is the central office for all contracting activities. If you have a specific question you can find the appropriate contact in the OAS directory. There are several support tools available to help you understand how to do business with the EPA. The EPA also has its own acquisition regulations (EPAAR); parallel with the structure of the Federal Acquisition Regulation (FAR). EPA's Chief Information Officer has issued information directives to help the agency acquire information communication technology (ICT) products and services conformant to with Section 508 of the Rehabilitation Act, as amended (29 U.S.C. § 794d). This includes all ICT acquired at or below the Simplified Acquisition Threshold (SAT) and commercial items, including commercially available off-the-shelf (COTS) items.
Please review the Learn about Section 508 page in addition to the agency's policy and procedures page to determine if Section 508 and digital accessibility apply to a specific type of hardware, software, or other types of ICT.
All software, applications, and web content that are built, developed, or maintained on behalf of the EPA must be tested for Section 508 conformance using a methodology aligned with the U.S. Access Board ICT Testing Baseline. At this time that requires accessibility testing is conducted by a certified DHS Trusted Tester. All customized COTS must be tested by a certified DHS Trusted Tester prior to being moved into the production environment.
Be sure to review the US Access Board ICT standards for:
Accessibility Conformance Report (ACR)
An Accessibility Conformance Report (ACR) documents how ICT such as software, hardware, electronic content, and support documentation meet (conform to) the Revised 508 Standards for IT accessibility. A ACR must be provided for each ICT item that is developed, updated, and configured for the agency, and when product substitutions are offered.
Government solicitations that include ICT will specify accessibility requirements, indicating which provisions are required to ensure the deliverable is accessible. A ACR addresses the accessibility requirements defined in the solicitation.
Use the ACR to make specific statements in simple recommended language to demonstrate how the features and functional characteristics of your product meet the Revised 508 Standards.
ACRs help EPA contracting officials and government buyers assess ICT for digital accessibility when doing market research and evaluating proposals. To be considered for the award, an ACR must be submitted for each ICT Item and must be completed according to the VPAT instructions provided by ITIC. The EPA recommends that all vendors:
- Post a copy of a ACR as part of the product descriptions accessible from their websites for all products being marketed to the federal government.
- Update the ACRs regularly to provide accurate information related to the current version or build of each ICT.
- Create the ACR using a manual testing methodology that aligns with the US Access Board ICT Testing Baseline.
Voluntary Product Accessibility Template (VPAT®)
A Voluntary Product Accessibility Template (VPAT®) is the industry standard template used to create a ACR. Learn more about how a ACR is created from using the VPAT from guidance provided by NASA and GSA. We recommend that vendors generate a ACR using the VPAT® for any ICT that’s intended to be marketed to the Federal government.
- Download the current VPAT® template from the Information Technology Industry Council (ITI) website.
Vendor Responsibilities for Content Creation in Contracts
All vendors must create and provide contract deliverables that are digitally accessible and conforming the appropriate Section 508 standards. Even though the final product might be excluded or be an exception to Section 508 compliance, the supporting documentation must conform to the appropriate Section 508 standards. GSA has an excellent site on how to create documents, presentations, and other contractual deliverables compliant. Even if you don't think that you are working with an individual with a disability now - you might not realize it. Your documents will be available to EPA employees and in some cases might interact with the public for years. It's important that original documentation be accessible from the first moment.
At the EPA, we work diligently to get every internal and external website digitally accessible. We also strive to have all of our internal agency training digitally accessible. The EPA wants its vendors to consider Section 508 compliance as just another routine federal contracting deliverable requirement.
Digital accessibility activities are in direct support of EPAAR 1552.211-79 (c) which states: Section 508 requirements (accessibility). Contract deliverables are required to be compliant with Section 508 requirements (accessibility for people with disabilities).
Your EPA solicitations and contract awards should include a clause pertaining to 1552.211-79 (Compliance with EPA Policies for Information Resource Management).
EPA encourages vendors and developers to follow federal and industry best practices when developing, evaluating, documenting accessible ICT depending on type.
- Software, Websites and Applications
- Electronic Content: documents, spreadsheets, and pdfs
- Accessible Electronic Documents Community of Practice (AED COP) of the Federal CIO Council guidance and checklists
Federal Acquisition Regulation (FAR) References
Federal agencies must follow the FAR when supplies and/or services are purchased. In August 2021, the FAR was amended to incorporate revisions and updates from the Section 508 standards.
- Revised 508 Standards, Safe Harbor, and FAR Update
- Federal Acquisition Regulation: Section 508-Based Standards in Information and Communication Technology
- Tabular Comparison of the Previous FAR text against the 2021 Update
General Services Administration (GSA) Guidance
GSA provides a large volume of resources and tools pertaining to Section 508 on Section508.gov: