Section 508 Checklist (2021) | Compliant

The Rehabilitation Act of 1973 is one of the most important pieces of legislation as it relates to protecting those with disabilities.

Whereas the Americans with Disabilities Act covers equal access in places of public accommodation, the Rehabilitation Act prohibits discrimination on the disabilities in programs and services conducted by federal agencies.  

While accessibility for individuals with disabilities was the primary goal of the act, an amendment was made in 1998 to address accessibility issues as it related to the growing use of information and communications technology.

What Is Section 508?

As mentioned, there was an amendment to the Rehabilitation Act that sought to address the issues of web accessibility, mainly information technology associated with federal agencies. So, the U.S. Congress amended the Rehabilitation Act to require all federal agencies to make their electronic and information technologies accessible to individuals with disabilities.

This amendment is known as Section 508. According to the law, Section 508 applies to all federal agencies when they develop, procure, maintain, or use communications and information technologies, this includes content on websites and multimedia.

Per the definition outlined in Section 508, information technology refers to any equipment or interconnected system of equipment that is used to acquire, store, manipulate, manage, display, or transmit information or data.

In terms of what constitutes communications and information technology (ICT), examples include but are not limited to:

• Software application and operating systems.
• Official website and federal web pages.
• Online training, webinars, and teleconferences.
• Technical support centers and remote access tools.
• Fax machines, printers, copiers, electronic documents (PDFs), and more.

The law applies to individuals with disabilities that are federal employees as well as members of the public.

What Are Section 508 Requirements?

The U.S. Access Board is responsible for developing ICT accessibility standards and issues the requirements for Section 508. In 2017 the Access Board issued a final rule for accessibility requirements and refreshed guidelines relating to telecommunications products.

Also, it is important to note that the Office of Accessible Systems and Technology (OAST), part of the Department of Homeland Security, also offers guidance to help agencies remove barriers to accessing ICT. The amendment covers general exemptions, definitions, and various applications for ICT.

Section 508 is broken down into technical standards as they relate to different elements of ICT. Let’s briefly take a look at each.

Software applications and operating systems

This refers to the accessibility to software. For example, software must be designed so it is executable from a keyboard, not only a mouse.

Many individuals with disabilities rely on keyboard navigation to access content, applications must be optimized to meet that need.

Web-based intranet and internet information and applications

This covers accessibility when it comes to page content. This could include providing alternative text (alt text) for complex images of visuals or graphics on a website. Some individuals with visual impairment (e.g. low vision or blindness) use screen readers to interpret content from a website, having a text equivalent is key.  

This could also include layout, ensuring all column and row headers are properly identified for data tables, or using markups to associate data cells and header cells for data tables that have multiple levels of rows and columns headers.

Videos or multimedia products

This standard covers the requirements for audio descriptions of multimedia. This could involve a text description, transcripts, or captions for video content. Federal agencies are required to provide hearing-impaired individuals with some form of a script for audiovisual content, whether it be for training and informational content.

Telecommunication products

This standard relates to accessibility for telecommunication products, such as voice mail systems or cell phones. These must be compatible with assistive technologies, like hearing aids, listening, devices, etc.

Self-contained, closed products

This addresses products that are not compatible with the end user’s assistive technologies (e.g. fax machines, copiers, etc.). Generally, this standard overlaps with other standards.

Portable computers and desktops

This standard addresses accessibility as it relates to mechanically operated controls (e.g. touch screens or keyboards).

What Are 508 Compliant Documents?

Section 508 does offer accessibility compliance checklists for conformance to standards for developing accessible web content and documents. Per Section 508, documents would include Microsoft Office applications (Word, Excel, PowerPoint) and Adobe PDF. Requirements include color, links, images, tables, form fields, and more.  

Also, websites and web applications are also considered documents per Section 508. Best practices for the implementation of accessible design are outlined in the Web Content Accessibility Guidelines (WCAG).

This covers instruction for use of color (e.g. background color and foreground), text alternatives, multimedia precautions for seizures, and more.

How Do I Check for Section 508 Compliance?

First, you must ensure Section 508 applies to you. Generally, it applies to all federal agencies. However, it also affects organizations that do business with federal agencies. This could include private contractors, vendors, and web managers.  

A reference to ensure compliance would be the guidelines mentioned above (WCAG). But, the Department of Homeland Security does have a testing process to validate conformance claims.

Purpose

Organizations looking to be proactive can also choose to apply their own compliance testing, which could involve automated, manual, or hybrid testing methods. The purpose of conducting Section 508 compliance testing is to ensure your organization’s digital content is in conformance to the Web Content Accessibility Guidelines.

Audience

Implementation of accessible design requires you to know your audience. In terms of accessibility, the audience will include those with disabilities, such as those with visual and hearing, physical, and cognitive impairments, and learning disabilities.

General Content

The WCAG sets the standard for what determines accessible content. Again, per the language of Section 508, this could be documents and content on web pages. As a rule, the general content on the website should be:

• Perceivable – All information and user interface components must be presented in a way that is easily understood by the audience. It cannot be invisible to the senses.
• Operable – Users must be able to navigate the content easily. That means optimizing the website and all elements for different forms of navigation (e.g. keyboard). There should be no barriers to interact with content.

• Understandable – The content and components should be understandable to the user. This includes elements such as images or diagrams. Alternative texts must be given for anything that provides context to understand.

• Robust – The content must be robust, meaning it can be interpreted reliably by various assistive technologies.

Color and Other Screen Elements

The use of color is also important. Using an accessible color palette is key for providing equal access for those with visual impairments, like color blindness.

Also, WCAG sets standards for color contrasts (text and foreground vs. background). Minimum color contrast ratios for body texts should be at least 4.5:1.

Other screen elements that are part of an inactive user interface component (decoration) do not have contrast requirements. Only items that supplement for context.

Audio and Video

Captioning must be provided for audiovisual content. This includes audio-only (podcasts), video-only, and videos with audio content. These must be synchronized; per the WCAG, automatic captions are not sufficient to meet minimum accessibility requirements.

Bandwidth and Data Capacity

Low bandwidth input and data capacity are real issues for some people, this can lead to interface issues. Usually, this issue lies with the web browser. From an accessible design standpoint, translating HTML into a more accessible layout can sometimes help. Also, providing shortcut keys to access important links is also suggested.

Maintenance

Section 508 outlines maintenance protocols for all technical standards. However, accessibility can also be maintained through routine testing, like the ones mentioned above. Automated testing tools are the best way to ensure continued conformance.

System Assessments

The same rule applies to system assessments, whether it be for software applications or a website. Again, there are a variety of assessment tools that can be used.

Conclusion

Section 508 of the Rehabilitation Act remains one of the most important pieces of legislation as it relates to equal access to communications and information technology for those with disabilities.

Although Section 508 deals specifically with federal agencies, all entities that do businesses with federal agencies could all be subject to the provisions.

Section 508 addresses how communications and information technology are to be developed, procured, maintained, and used. This includes content on the web as well as any technology or equipment that is used to acquire, display, or transmit information.

At the end of the day, Section 508 compliance helps prevent discrimination against those with disabilities, offering them equal access to the content and services on the web.